The United States Postal Service is publishing a Federal Register notice with the final ruling on the price eligibility for commercial flat size pieces that fail the deflection or "droop" test. The USPS published the proposed rule on this topic in December 2009, and based on the comments received on that posting, have now issued the final ruling. As background, the USPS first planned to make the new deflection standards effective in May 2009, which was then postponed and then finally deferred to become effective on June 7, 2010.

We provided information on these changes in our November 12, 2009 and December 3, 2009 E-tips.

The Rules
In this final ruling, the USPS has not made any changes from its original proposed changes in the specifications for flats eligibility or in the flats deflection testing. The changes in this final ruling only involve the pricing that will apply to commercial flat size pieces that fail these specifications/testing. As a refresher, the revised standards will extend the flats deflection standards currently in place for automation flats to all flat size mail, with the exception of flats mailing at Periodicals or Standard Mail saturation or high density rates. Pieces mailing at Periodicals or Standard Mail saturation or high density rates do not need to meet these requirements.

The revised deflection standards reduce the allowable droop by 1 inch (from 4 inches to 3 inches for pieces that are at least 10 inches long). The new standards also eliminate the exception for oblong flats (those with a bound edge on the shorter side). All flats will now be tested placing the length perpendicular to a flat surface.

The Testing
There were a number of comments on the December proposed ruling that dealt with the testing procedures for determining whether flat size pieces meet the deflection criteria. Mailers are concerned that there is not a standard tool for conducting these tests and that as a result there would be incorrect or inconsistent rulings. In response to these concerns, the USPS is developing sampling procedures and making modifications to the testing processes to provide for more objectivity.

The USPS encourages mailers to work with local Mailpiece Design Analysts to evaluate flat size mailpieces so that necessary adjustments may be made to bring the pieces into compliance. The USPS will also be using its Electronic Mail Improvement Reporting system (eMIR) to report to mailers when they encounter mailpieces that cause problems on sorting equipment.

The Pricing
Initially, the USPS planned to impose parcel rates or Not Flat Machineable (NFM) rates for pieces which failed the new standards. This has now been revised so that, in general, the penalty for failed pieces is the non-automation rates for the applicable class of mail.

For First-Class Mail presorted flats that will pay single-piece prices, the presorted marking must be obliterated or corrected via the addition of a "single-piece" marking. For all other classes of mail, the original sortation can remain as prepared. The pricing impacts of failed deflection tests are detailed in the tables below.

NOTE: Although the revisions to the flat deflection requirements become effective June 7, 2010, the implementation of postage consequences for failing these standards does not become effective until October 3, 2010.

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