Customer Support Ruling

Saturation Requirements for Detached Address Label Mailings
Updated October 1996

PS-276 (602.4.1.2)

This Customer Support Ruling discusses detached address labels and the saturation requirements for Periodicals and Standard Mail flats.

Recently a few mailers have requested waivers to allow them to prepare detached address label mailings of Periodicals and Standard Mail flats that do not meet the saturation requirements prescribed in DMM 602.4.1.2.  The mailers argued they could not apply address labels to each mailpiece due to their tight production schedules, and that their local postal officials had stated they preferred to handle mailings with detached address labels regardless of the level of saturation.  These requests for waivers were denied for the reasons stated below.

Postal processing of mailings with detached address labels requires different handling considerations to ensure that an address label is matched to a corresponding unaddressed portion of the mailpiece before delivery occurs.  The use of detached address labels was created as an addressing alternative based on the finding that such use is efficient when most of the addresses on the route will receive the mailpiece.  When the coverage of the route drops below the established percentages for saturation coverage, the use of detached address labels is generally not as efficient.  While some post offices may be able to handle an individual detached address label mailing that is below the required saturation level, the Postal Service's overriding responsibility is to apply mailing rules consistently to all of our customers.

A second critical element involved is our binding commitment to the bargaining unit agreement which places limits the number of extra "bundles" our carriers may carry.

Accordingly, it is not in the best interest of the Postal Service to grant individual requests for waivers to the existing standards in DMM 602.4.  The Postal Service is bound to treat all customers equitably by Title 39 U.S.C. 403(c) which states: "In providing services and in establishing classifications, rates, and fees under this title, the Postal Service shall not, except as specifically authorized in this title, make any undue or unreasonable discrimination among users of the mails, nor shall it grant any undue or unreasonable preferences to any such user."

At this time, the Postal Service also does not plan to take action to lower the DMM saturation requirements, since as previously cited, the wider use of mailings with detached address labels would not be in our best interests.  The different handling considerations generally involve greater handling costs.  Therefore, all mailings prepared using detached address labels must meet the applicable saturation level requirements specified in DMM 602.4.

(Signed)
Anita J. Bizzotto
Manager
Mailing Standards
United States Postal Service
Washington DC 20260-3436