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24-Jan-2011
Flat Rate Priority Mail have been in use for a number of years. It has always been the rule that one might stuff these envelopes with any mailable content, regardless of thickness, or contour, or weight up to 70 pounds for domestic use and 4 pounds for international use.
Since December, a number of postal stations have been improperly refusing to accept Flat Rate Envelope mailings when they are "too thick" or are "poofy" or "lumpy."
This article spells out what the official postal regulations are, and outlines procedures you may use to communicate with the Postal Service.
As a companion, see these letter fragments to appeal refusals of FREs.
The primary rules governing the mail are the Domestic Mail Manual and the International Mail Manual. The regulations within these documents are definitive, and they provide for nationwide consistency in the rules. These documents are available online (which is quite up to date), and are available in hard copy at some postal stations although these hard copy versions are updated less frequently.
The DMM section 123.1.5 says:
"Any amount of material (up to 70 pounds) may be mailed in a USPS-produced Priority Mail Flat Rate Envelope or Flat Rate Box."
"When sealing a Flat Rate Envelope or Flat Rate Box, the container flaps must be able to close within the normal folds."
"Tape may be applied to the flaps and seams to reinforce the container, provided the design of the container is not enlarged by opening the sides and the container is not reconstructed in any way."
Notice that there is no specified restriction concerning thickness or for uniformity of surface contours. There are no restrictions about thickness or contour anywhere in the DMM.
Also note that once the envelope is sealed by it's own adhesive, you may then reinforce the seams and flap with tape. What you want to do is make it plain that the latitude afforded by the envelope's own construction was not exceeded.
Sometimes a postal clerk or official will object about a FRE for one of these reasons, all of which are misinterpretations of the DMM.
Bogus objection 1: A thick FRE is forbidden because the flap is not folded sharply or folded exactly on the flap crease. That is an incorrect restriction. The regulation says "within," not "on." For example, the flap may be folded inside that crease, yielding a packet that's shorter than the typical 9 inch height. This interpretation has been upheld in appeals.
Bogus objection 2: A thick FRE is forbidden because the bulging envelope means that the envelope has been "enlarged." This is an incorrect interpretation of the wording, the intent, and practical reality. The operative words are not "enlarged," but "enlarged by opening the sides." This clarification was added to the DMM because once upon a time some mailers were slitting FREs in half and taping the front and the back to large packages. And you may not do that.
Bogus objection 3: A thick FRE is forbidden because it contains something other than documents. DMM 123.2.1 allows that "Priority Mail ... may contain any mailable matter" and does not restrict FREs to "documents."
Bogus objection 4: A thick or lumpy FRE is forbidden because the container must be "flat." Again, DMM 123.2.1 allows that "Priority Mail ... may contain any mailable matter" and does not demand flatness.
Bogus objection 5: A FRE thicker than 3/4" is forbidden because a) it is an envelope, and b) the First Class Mail measuring doodad says that "Large Envelopes" must not be thicker than 3/4". Oh brother, where to begin. First of all, that First Class Mail measurement doodad is intended only to determing if a mail piece qualifies for First Class Letter rate, First Class Large Envelope rate, or First Class Parcel rate. The doodad has nothing to do with Priority Mail. Again, DMM 123.1.5 does not restrict thickness in any way.
An article containing incorrect information was published in a late December 2010 issue of the Retail Digest, which is a newsletter type of publication distributed by USPS Marketing to all Postmasters. This article said that thick and lumpy Flat Rate envelopes were improper usage of the envelopes. The Retail Digest does not establish regulations or policy.
A flyer, which was reportedly included as an attachment to this issue of the Retail Digest,bears a photo of a thin FRE annotated "YES!" and a lumpy FRE annotated "NO!". The flyer does not state any regulation. The flyer is completely at odds with the regulations as specified in the DMM. Nevertheless, some post offices are posting this flyer in their lobby and using it to improperly instruct postal clerks.
Some post offices immediately recognized this was inconsistent with the DMM, and ignored it. However, some branches accepted this as proper doctrine and began enforcing it as such.
It's reported that the post office rescended the message in the article in early January. For whatever reason, some post offices have not gotten the word.
We should expect that the Postal Service will observe it's own written rules uniformly across the nation. When a clerk or office does not follow the rules, we should expect that anyone may escalate the issue up the supervisory chain, to have the issue fairly heard, and if higher ups rule in favor of the customer, that the higher ups will reinstruct his or her subordinates.
We should not tolerate the USPS acting arbitrarily, nor to ignore or sidestep reasonable complaints that actions are contrary to regulations.
We expect the Post Office to accept FREs that contain lumpy things like tennis balls or thick things like 2 inch thick boxes, provided they are properly sealed, within weight limits, and contain mailable content.
If your postal clerk rejects your mailing, here is how you can productively work the issue.
You follow the chain of command upwards until you reach the someone who will rule in your favor. Then that person will communicate the correct directive goes back DOWN to your postmaster refusing to accept the FRE.
At each step, State the issue. (Clerks refuse to accept my FRE because it's too thick.' That's contrary to postal regulations, specifically the Domestic mail manual).
Be polite, professional and to the point.
The chain of command will lead to the Postmaster. If the postmaster doesn't give a satisfactory answer, ask for the postmaster's superior's name and direct phone number, which may well be a District Office. Generally, the District Offices are more knowledgable about the rules than are the Postmaster. Follow that lead up the chain.
If the direct chain of command stumps you, contact first the manager of your local Bulk Mail Entry unit, and, that failing, contact the Pricing and Classification Service Center (PCSC). Either your postmaster or the District Office fail can tell you who your nearby Bulk Mail Entry manager is.
The PCSC can be useful in another way. When speaking with a postmaster or someone District Office, you can direct them to the PCSC, saying that they are conversant with this issue and can quickly guide the Postmaster.
The Bulk Mail Entry manager will very often resolve the problem sensibly. These are professionals who know the rules, deal in greater volumes, and have better experience. You can expect that they are intimately conversant with the DMM and have access to it if you query fine points.
However, if your BME manager disagrees with your interpretation of the rules, or is uncertain, the next step is to the PCSC. Taking this next step doesn't mean you're wrong - there are fine points. You may ask the BME manager to assist you in submitting a package to the PCSC for consideration. The BME managers are polite and are glad to help. I suspect that they view it to be in their interests to fascilitate the resolution of fine points. Professional managers view it that way.
The PCSC is open from 8:30 a.m. to 7 p.m. Eastern Time. Contact the PCSC as follows:
Pricing and Classification Service Center United States Postal Service 90 Church Street, Suite 3100 New York, NY 10007-2951 212-330-5300 212-330-5320 (fax)
