Tab Seal Guidelines

On December 29, 2008, a proposed rule was published in Federal

Register (73 FR 79430-79435), that provided information on changes to tab

placement and construction of folded self-mailers and booklets. The proposed

General

This final rule includes the new required DMM standards for design,

preparation, and sealing of machinable and automation letter-size booklets. We

also describe in this final rule, recommended upgrades to the new requirements.

We base these recommendations on observations of a wide variety of booklets

tested and observed over the past several years. Following these

recommendations will minimize mailpiece damage and maximize the efficient

processing of booklets.

Definition

Booklets consist of bound sheets or pages. Binding methods that are

compatible with machinable processing include perfect binding, permanent

fastening with at least two staples in the manufacturing fold (saddle stitched),

pressed glue, or another binding method that creates a nearly uniformly thick

mailpiece. Spiral bindings are not machinable so booklets prepared with spiral

bindings do not qualify for automation prices. Large booklets may be folded to

letter-size for mailing if the final mailpiece remains uniform in thickness.

Physical Characteristics

The maximum height for all machinable and automation booklets is six

inches and the maximum length can vary between 9 and 10-1/2 inches,

depending on the booklet design. The minimum thickness for booklets is 0.009

inch and the maximum thickness is 0.25 inch regardless of size. Thickness is

measured at the spine of the mailpiece.

The current maximum weight of 3 ounces has not changed and is

applicable to all mailpieces prepared without envelopes. However, to improve

machinability we recommend reducing the length of 3-ounce booklets to a final

trim size of 9 inches.

Cover stock requirements vary with 40-pound minimum basis weight for

folded booklet designs and 60- or 70-pound minimum basis weight for pieces

longer than 9 inches. Lighter-weight paper tends to be easily damaged in

processing equipment. The use of paper that is 10 pounds heavier than the

required minimum basis weight is recommended for better processing

performance. We strongly recommend using a minimum of 70-pound paper as

cover stock on mailpiece designs that approach maximum booklet dimensions.

References to paper weights are for book-grade paper unless otherwise

specified. A paper grade conversion table is included in DMM Exhibit 201.3.2 for

reference.

The bottom edge of booklets must be a bound edge or fold unless the

mailpiece is prepared as an oblong booklet. Oblong booklets must be prepared

with a spine on the leading edge. Booklets with a spine on the trailing edge are

nonmachinable.

Tabs used to seal booklets must not have perforations. Generally,

booklets need three 1-1/2 inch tabs as closures. For larger or heavier booklets,

we recommend 2-inch paper tabs. Glue spots or a continuous glue line may be

used to seal some booklet designs.

Booklets that do not comply with the new standards will not be eligible for

machinable or automation letter prices. Nonmachinable booklets will be

assessed a surcharge (for First-Class Mail®), pay nonmachinable prices (for

Standard Mail®), or pay nonbarcoded prices (for Periodicals).

We received more than 900 customer comments in response to the

proposed standards. Of these, 79 noted concerns about booklet design changes.

Many commenters expressed concerns about multiple issues. Below we describe

all comments and not those exclusively about booklets.

There were 442 comments concerning tabs without perforations. Of these,

287 were form letters or parts of form letters stating that tabs without perforations

would make mailpieces hard to open for the elderly and infirm. Six came from

manufacturers of tabs. Two mail preparers claim that mail with solid tabs went

unread. At the request of a group of mail owners, one mail preparer completed a

6-month study of response rates to mailpieces prepared with three solid tabs. No

appreciable change in response rate occurred.

Booklets with tabs that fail during high-speed processing sustain damage

and cause damage to other mailpieces. Our tests revealed that tabs with

perforations are easily broken, often do not maintain their integrity, and are

damaged in transport prior to entering the mailstream. To minimize tab failure,

tabs used to seal booklets claiming automation or machinable prices may not be

perforated. Solid tabs made of plastic, vinyl, translucent paper, opaque paper, or

cellophane tape is acceptable.

Tab placement generated 401 responses. Commenters cited the lack of

machinery capable of applying two tabs on the leading edge and one tab on the

trailing edge of each booklet, the cost of upgrading existing tabbing equipment,

and the amount of extra space required to install upgrades as reasons why they

objected to the proposed standards for tab placement. Three commenters stated

that the tabbing systems they purchased would become obsolete because they

can only apply tabs on the top open edges. There were 170 mailers concerned

about tab size. They objected to the introduction of minimum tab sizes that

exceed one inch because their equipment couldn’t apply tabs larger than one

inch.

We realize that using different size tabs on booklets, adding an additional

tab to the leading edge, and affixing them in locations that were until now

optional, will require some adjustments to customer manufacturing processes.

Some customers are already producing and mailing booklets with the tabbing

configurations required by the new standards despite the obstacles mentioned. In

addition, at least one manufacturer of tabbing machines is advertising a unit with

the capability of tabbing mail in the proposed locations.

Mailer and controlled tests demonstrate that using 1-1/2 inch tabs to seal

booklets in place of the smaller 1-inch tabs improved the productivity of

processing. Sorting booklets sealed with 1-1/2 inch tabs still reduced machine

throughput compared to processing other letter-size pieces. To improve

productivity and processing, 1-1/2inch tabs are required. We will continue to

monitor booklet processing performance.

The increase in the number of tabs required to seal booklets generated

179 comments. Remarks focused on the absence of notification, with some

commenters stating that the mailings they present now are not generating error

reports from the plants that process them. As booklet volumes increase in the

mailstream, processing operations must divert these mailings to manual or flat

mail operations to avoid mailpiece damage and machine down time. The USPS

generated numerous irregularity reports concerning poorly prepared booklets

over the past several years. These reports have documented instances of

jammed machines and torn mailpieces. Our experiences processing booklets as

live mailpieces and in a variety of controlled and customer-supplied mailpiece

tests show that the new standards are needed. Customers who observed their

own booklets being tested acknowledged that although their mail is currently

being charged automation or machinable prices, it cannot be machine sorted.

A number of commenters stated that we did not justify the amount of

added workload applying additional tabs would impose on the customer. Testing

demonstrated that the machine throughput when processing booklets with two 1-

inch tabs on the top edge was half the throughput for booklets with two 1-1/2 inch

tabs on the lead edge and one tab on the trailing edge, and almost one fourth the

throughput for enveloped letter mail. Therefore, we believe this warrants the

changes.

Many commenters objected to the definition of a folded self-mailer. The

definition of folded self-mailers will be refined in conjunction with a subsequent

phase of testing customer-supplied samples and will be published at a later date

as part of the changes to folded self-mailer standards indicated by test results.

Only 31 customers expressed concerns about standards for static charge

and coefficient of friction. Some commenters wanted to know where to buy paper

that conformed to the standards while others asked how mail would be tested for

these characteristics in the acceptance units. We recommend this requirement

while further methods are explored to measure these standards. We recommend

testing your mailpieces for static charge and coefficient of friction when possible.

Forty-nine commenters asked that we delay changing standards for

booklets and folded self-mailers until the economy turns around. We believe that

implementing standards for booklets will improve the processing and cost

effective handling of these pieces. However, we will work with the mailing

community to further refine standards for folded self-mailers.

Some commenters wondered how they could determine if their mailpiece

was made of high tear strength paper. Paper distributors generally recognize

which of their products have high tear strength, and most papers sold in office

supply stores have adequate tear strength. High tear strength paper has

properties like a high fiber length, a low degree of beating, and for machine-made

papers, fiber orientation. Mailpieces made of high tear strength paper can be

sorted on automated processing equipment without tearing or shattering.

Some commenters objected to the increase in required paper grade for

the covers of booklets. Paper values published in the DMM varied by product.

Our new booklet illustrations and descriptions are based on book-grade paper.

Paper grades are printed on the packaging of reams, boxes, and rolls of paper.

The maximum weight of automation letters was a concern for some

customers. The proposal did not change the maximum allowable weight for

booklets. According to current standards in DMM 201.3.14.4, letters that weigh

more than 3 ounces must be prepared in a sealed envelope, therefore booklets

weighing more than 3 ounces must be prepared in sealed envelopes. Our

standards reflect this required mailpiece characteristic.

Based on the results of continued testing, a modification to the standards

was published in the Federal Register on December 29, 2008, increasing the

amount of acceptable tab overhang from 1/32 of an inch to 1/16 of an inch.

The Postal Service adopts the following changes to Mailing Standards of

the United States Postal Service, Domestic Mail Manual (DMM), incorporated by

reference in the Code of Federal Regulations. See 39 CFR 111.1.

Administrative practice and procedure, Postal Service.

Accordingly, 39 CFR 111 is amended as follows.

Authority: 5 U.S.C. 552(a); 39 U.S.C. 101, 401, 403, 404, 414, 416, 3001-

3011, 3201-3219, 3403-3406, 3621, 3622, 3626, 3632, 3633, and 5001.

2. Revise the following sections of Mailing Standards of the United States

Postal Service, Domestic Mail Manual (DMM) as follows:

All pieces of First-Class Mail and Standard Mail machinable letters must meet the

standards for automation-compatible letters in 201.3.0. * * *

Letters and cards claimed at any machinable, automation, or Standard Mail

carrier route price, must meet the standards in 3.0. Unless prepared as a folded

self-mailer, booklet, or postcard under 3.14 through 3.16, each machinable or

automation letter must be a sealed envelope (the preferred method) or, if

unenveloped, must be sealed or glued completely along all four sides.

Mailpieces should be constructed from high tear strength paper stock. All

references in 3.0 to paper basis weight are for book-grade paper unless

otherwise stated. The conversion table in Exhibit 3.2 provides a paper basis

weight cross-reference.

Each machinable or automation letter-sized piece must be rectangular (see

1.1.1) and must meet the following standards (see 3.15 for booklets):

The following maximum weight limits apply:

a. Booklets and folded self-mailers — 3 ounces.

b. Machinable enveloped letters and cards — 3.3 ounces.

c. Automation enveloped letters and cards — 3.5 ounces (see 3.6 for pieces

over 3 ounces.)

Heavy letter mail (letter-size pieces over 3 ounces) must be prepared in a sealed

envelope, may not contain stiff enclosures, and must have an 11-digit delivery

point POSTNET or an Intelligent Mail barcode with a routing code in the address

block (see 202.5.0).

* * * * *

Tabs on booklets must be at least 1-1/2 inches in width. The tab placement

standards in 3.15 are subject to 1/4-inch variance in either direction. Tabs may

be made of opaque paper, translucent paper, vinyl or plastic, and must not

contain perforations. Cellophane tape may also be used as a closure. The

following standards also apply:

a. Translucent paper tabs should be made of paper with a minimum of 40-

pound basis weight.

b. Opaque paper tabs should be made of a minimum of 60-pound basis

weight paper with a tear strength of at least 56 grams of force in the

machine direction (MD) and 60 grams of force in the cross direction (CD).

c. Tabs in the barcode clear zone must have a paper face meeting the

standards for background reflectance and, if the barcode is not preprinted

by the mailer, the standards for acceptance of water-based ink.

d. Vinyl tabs and cellophane tape closures are not acceptable within the

barcode clear zone.

e. Tabs must be tight against the edge of the mailpiece. A maximum

1/16-inch overhang is recommended.

f. Glue spots may be used in lieu of tabs and must be placed within 3/4 inch

of the open edges (see Exhibit 201.3.11.f).

g. Continuous glue lines may be used as cover-to-cover seals and must be

placed along the entire length of the open edge and end no more than 3/4-

inch from the open ends (see Exhibit 201.3.11.g).

Booklets must have a bound edge. Sheets that are fastened with at least two

staples in the manufacturing fold (saddle stitched), perfect bound, pressed-glued,

or joined together by another binding method that produces an end where pages

are attached together are considered booklets. Booklets are open on three sides

before sealing, similar in design to a book. In general, booklets must be uniformly

thick. Large bound booklets that are folded for mailing qualify for automation and

machinable prices if the final mailpiece remains nearly uniform in thickness.

Booklet covers generally must be made with a minimum paper basis weight of

60-pounds or equivalent. Minimum basis weights are higher for some designs

(see 3.15.4).

Booklets must be:

a. Height: not more than 6 inches or less than 3.5 inches high.

b. Length: not more than 10.5 inches or less than 5 inches long. See Exhibit

3.15.4 for some booklet designs with shorter maximum lengths.

c. Thickness: not more than 0.25 inch or less than 0.009 inch thick.

d. Weight: not more than 3 ounces.

e. Aspect ratio: within 1.3 to 2.5 (see 201.3.1).

Booklets may be designed with the spine or final fold at the bottom or on the

leading edge. See Exhibit 3.15.4 for design and sealing standards.