Testimony of-Continued Palmquist, Oscar E., president, National Council on Business Mail, Trischett, Donald S., American Paper Institute, New York, N. Y. Page 29 21 11 117 101 Weil, Leslie J., president, Envelope Manufacturers Association, accompanied by William H. McManus, executive vice president, Envelope Manufacturers Association. 127 Statement submitted by Greene, Robert S., executive director, National Association of Advertising Publishers___ 11 80 Hilliard, Carey W., president, National Rural Letter Carriers' Asso ciation. Communications from Daly, John Jay, vice president, Direct Mail Advertising Association, Additional material H.R. 14029, subject of hearing 86 Tabulation of history of growth of subclasses of third-class mail____ 65 STANDARDIZING THE SIZES OF MAIL WEDNESDAY, FEBRUARY 28, 1968 HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON POSTAL RATES OF THE COMMITTEE ON POST OFFICE AND CIVIL SERVICE, Washington, D.C. The subcommittee was convened at 10:10 a.m. in room 210, Cannon Building, Hon. Arnold Olsen (chairman) presiding. (The bill, H.R. 14029 is as follows:) [H.R. 14029, 90th Cong., first sess.] A BILL To fix additional postage charges for certain nonstandard mail, and for other purposes Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That chapter 69 of title 39, United States Code, is amended (1) by adding at the end thereof the following new section: "4656. Nonstandard mail "(a) Each piece of nonstandard airmail or of nonstandard mail of the first class, weighing not more than two ounces, is subject to an additional postage charge of 2 cents a piece. "(b) As used in this section, nonstandard mail means mail which does not conform to all of the physical characteristics of standard mail as defined by the Postmaster General in accordance with law."; and (2) by adding to the table of contents thereof the following: "4656. Nonstandard mail." SEC. 2. (a) The Postmaster General is authorized and directed to conduct a comprehensive study of the physical characteristics of mail handling in the postal service, including among other matters (1) a review of present and anticipated mailing patterns which have or may have an effect on present or future plans of the Post Office Department for accelerated use of the processes of automation and mechanization in connection with the handling of mail; (2) a survey of the types of mail processing machinery currently in use in order to determine (A) their capabilities, (B) their suitability to serve the needs of the mailing public, and (C) their potential for improved efficiency and greater adaptability to use in the processing of a broader range of mail matter; (3) a review of research and development programs, in the Federal Government and in private enterprise, which are directed toward, or may be utilized in the development or improvement of machinery suitable for expeditious and efficient mail processing, with particular reference and attention to the potential for optimum use and performance of machinery in the processing of mail matter of a variety of sizes, dimensions, and other characteristics sufficiently broad to serve the mailing needs of the general public; (4) a review of the concept of establishing size and dimension limits and other physical characteristics with respect to mail matter, in connection with the processing thereof by automation and mechanization, as well as with the delivery thereof, in order to determine whether and to what extent there are practicable and reasonable size and dimension limits with respect to mail which can and should be established in the public interest; (5) the development and collection of comprehensive information and evidence with respect to the impact of mail size and dimension limits on (A) the users of the mails generally, (B) the various segments of business and commerce, and (C) postal operations; and (6) the feasibility of adopting size and dimension limits and other physical characteristics with respect to domestic mail matter consistent with those which are in effect, or which have the status of executory propositions, under the Convention of the Universal Postal Union. (b) The Postmaster General shall publish in the Federal Register his findings made as a result of the study conducted pursuant to subsection (a) of this section and shall include therein proposed regulations defining standard airmail and standard mail of the first class. Thereafter proceedings shall be had on such proposed regulations pursuant to section 553 of title 5, United States Code, except that standards prescribed pursuant to this section shall not become effective until at least two years after the date the regulations in which they are set forth are published in the Federal Register and transmitted to the Congress by the Postmaster General. Mr. OLSEN. The subcommittee will come to order. This morning the subcommittee is resuming its hearings on the subject of standardization of mail sizes. At the initial hearing on this subject, held in November of last year, the subcommittee heard testimony from officials of the Post Office Department. Today, and at subsequent hearings, we will hear from those industries which would be affected by the passage of any legislation in this area. However, before hearing from today's witnesses, I think it would be wise, in view of the amount of time that has transpired since the November hearing, to review the testimony given by the Department at that time. The departmental witnesses indicated that, in their opinion, there are three areas involved in the discussion of mail size standardization: domestic first class and airmail; international letter mail; and thirdclass bulk mail. To deal with the problem of nonstandard-sized domestic letter mail, the Post Office recommended legislation that is incorporated in H.R. 14029, which was introduced, at the Department's request, by several subcommittee members and myself. H.R. 14029 would establish a procedure that would define standard letter mail and would assess, some 2 years after the formal publication of that definition, a penalty postage rate to be charged on nonstandard first-class mail and airmail letters of 2 ounces or less. In the matter of international mail, the Department proposed that the characteristics of domestic mail be checked against the pending characteristics of international mail. If the two are similar, there may be an opportunity to blend them into a single standard. However, it was pointed out that the ratio between domestic and international mail is 35 to 1, and that conformity to international requirements, taking into account this lopsided ratio, would hardly be fair to domestic mailers. Provisions for standardization of third-class bulk mail were absent from the Department's recommended legislation. The Department apparently feels that adjustments in this area can be made without the enactment of any specific legislation. Witnesses for the Post Office dwelt at some length on the problems they are experiencing with samples at the delivery end. However, I am confident that the subcommittee will hear testimony today in rebuttal to this contention. Finally, I want to again emphasize, as I did in the November hearing, that these hearings are of an exploratory nature. H.R. 14029 was primarily introduced to establish a starting point from which the subcommittee, the Post Office Department, and the mailing industry could work together toward a solution to at least one of the major problems besetting the postal service. Now, the first witness is Mr. James T. Cassidy, chairman of the board of Cassidy-Richlar, Inc. Mr. Cassidy, you have a gentleman with you? Mr. CASSIDY. Yes. Mr. Blinsinger. Mr. OLSEN. Fine, We are glad to have both you gentlemen. TESTIMONY OF JAMES T. CASSIDY, CHAIRMAN OF THE BOARD, CASSIDY-RICHLAR, INC.; ACCOMPANIED BY EDWARD BLINSINGER, PRESIDENT, CASSIDY-RICHLAR, INC., PHILADELPHIA, PA. Mr. CASSIDY. My name is James T. Cassidy. I am chairman of the board of Cassidy-Richlar, Inc., of Philadelphia, and president of the Advertising Distributors of America, Inc. If I may digress for a moment, it is a group of independent mailers, each one of whom owns their own shop throughout the country who cooperate on national mailings and the way this mailing is done is determined by the board of directors of Adveritsing Distributors of America, of which I am the president. We have asked for time before this committee in order to present the direct mail industry's approach to mail samples. In order that you might more fully understand, we have used a current mail sample job being performed by Cassidy-Richlar, Inc., for the Scott Paper Co., of Philadelphia, Pa. This is a sample of the mailing that we are using to illustrate various points. We feel it necessary to acquaint you with our client's reasons for mailing in a format that would definitely impose handling problems on the post office. Inside this mailing tube are six sheets of a new two-ply towel. In researching methods of mailing samples of towels to consumers, it was noted that the bulk of the product was materially reduced when the mailing was made in a flat mailing carton approximately the size of a single sheet of toweling. The bulk of the product was its principal asset over competitive products, and the client felt that if the product could not be delivered to the consumer with the bulk intact, it would be unnecessary to sample. Protective covering to protect the bulk was quickly judged impossible in any container that would be flat and tied and bagged in the normal mail delivery. The answer to the problem, a mailing tube [indicating]. Research indicated products mailed in this tube retain their bulk and are acceptable as a sample mailing device. The handling in mailing such a tubular device represents greatly increased costs to the Post Office Department. We do not argue this point. We agree. Your answer to this problem is an increase in postage. To this answer we do not agree. We feel that to increase postage to cover the cost of handling such a mailing piece would prohibit for all times sample mailings that encounter the problems discussed above. We do feel, however, that we have an answer to the problem, a simple effective answer; an answer that, under existing postal laws and regulations, in our opinion, is mandatory now. The postal laws and regulations state that the receiving postmaster may request cooperation in the makeup of any large mailing, including samples, that will affect efficiencies in handling and an efficiency in cost reduction. To prepare for the mailing of this sample, our organization and the client went to the Philadelphia Post Office and sat down with Mr. Anthony Lambert, the postmaster of Philadelphia. We frankly discussed with Mr. Lambert the research, its results, and the potential problems that it could bring to the Post Office Department. After intensive discussion, Mr. Lambert assigned a team of individuals from the Philadelphia Post Office and the regional center to immediately begin a series of meetings and discussions in view of circumventing the tremendous cost increase that would be borne by the Post Office Department in handling this sampling. In the course of the next 60 days, there were four meetings between the assigned postal personnel and the executives and production managers of Cassidy-Richlar, Inc. Scott Paper Co. was not involved, as they had given our organization carte blanche to cooperate to the fullest extent with the Post Office Department. May I list a number of facts that were derived from those meetings. I will attempt to list them in the order of their importance. 1. The greatly increased cost in handling some 16 million of these samples [indicating] is not involved in the actual house delivery of the samples, but the tremendous handling and transportation costs involved in moving the samples from the receiving platform of the accepting post office, of weighing for protection of revenue, spot checking samples, the internal movement within the post office of acceptance to transportation facilities from the accepting post office to the regional center involving the post office of delivery, the rehandling at the regional center, the handling and rehandling at the main post office of delivery, the primary sort to the various stations of the post office of delivery, the secondary sort to the carrier of delivery, and the casing of the mail by the carrier that would actually make the home delivery. 2. Any substantial saving to the Post Office Department had to be made from the point of acceptance of mailing to the point of actual home delivery. 3. Any change in the standard procedures would have to primarily involve postal transportation and protection of revenue. 4. A method to facilitate the handling of samples other than mailbags. 5. Cassidy-Richlar's coverage to the post office of delivery had to be predetermined for efficiencies of transportation. May we now list efficiencies that were inaugurated because of the above five points, and also attempt to convey to you the meaning for each move. 1. We eliminated the tying of samples and the bagging in mailbags. We substituted a mailing carton with a legend on both sides (holding up sample). This carton was engineered to accept exactly 300 of the mailing tubes. More could not be physically put into the carton, and less would be immediately apparent. By this method, we reduced 8 million samples to 26,667 mailing cartons. In predetermining exactly 300 units to a mailing carton, we |