Secure andEnvironmentally-Friendly Destruction of Undeliverable as Addressed (UAA) Mail

Tom Day – Chief Sustainability Officer, USPS®

Lisa West – Manager, Address Quality Programs, USPS

National Postal ForumMarch 17 - 20, 2013

Agenda

Sustainability and Secure Destruction

Description and Benefits

Update of Activities

Next Steps

Sustainability and Secure Destruction

FY11 operations 168.3 billion pieces

$65.7 billion in revenue

557K career employees

33,260 K facilities

24.2 (trillion BTU) Facility energy

711 (Million GGE) Transportation Fuel

151.5 M Delivery points

FY12 operations 159.9 billion pieces

$65.2 billion in revenue

528K career employees

32,604 K facilities

22.3 (trillion BTU facility energy

726 (Million GGE) Transportation Fuel

152.1 M Delivery Points

The USPS® challenge — less mail, limited capital, more addresses

Our Vision: Be A Sustainability Leader

Environmentally responsible secure destruction fits well with corporate goals

We are committed to be a sustainability leader by creating a culture of Conservation throughout the Postal Service™ and leading the adoption of Sustainable business practices by engaging our employees, customers, suppliers, the mailing industry, and our federal peers. As a foundation to this vision, we strive to ensure compliance with environmental regulatory requirements in all aspects of our operations. Our call to action is to be leaner, greener, faster, smarter in support of the overall goal to deliver mail at the lowest cost with minimal impact upon the environment.

USPS® Leadership Facility energy -33.9% vs 2003

Greenhouse Gas -9.9% vs 2008

Water Reduction -38.1% vs 2007

Reduce Consumables -38.8% vs 2008

47% of Waste is Recycled

All without tax dollars!

Undeliverable as Addressed Disposal

USPS® UAA Recycling Policy

• Seek practical and cost-effective ways

• Foster a “zero waste” ethic within the USPS

• Recycle consistent with public trust obligations

• Comply with laws and regulations

Returned 1.48 billion pieces of RTS First-Class Mail®

Opportunity to use secure destruction to improve environmental performance, cut costs, and enhance

value to customers

Secure Destruction

What is it?

What is Secure Destruction?

Secure Destruction describes a potential new mail program under consideration by the Postal Service™ that will allow mailers to opt to have mail, that would otherwise be returned-to-sender, disposed of in a secure manner.

This means that an undeliverable-as-addressed (UAA) mailpiece will be shredded by USPS® Employees at USPS facilities, to ensure the mailpiece will be rendered unreadable prior to disposal.

Proposed Participation Requirements Mailer must participate in Traditional ACS™,

OneCode ACS®, or Full-Service ACS to receive notice of disposed mailpieces

Mail must bear Intelligent Mail® barcode containing a Secure Destruction Service Type ID

Current Mail Preparation

Currently, First-Class Mail® is eligible for disposal onlywhen:

• ACS™ participant

• Change Service Requested Endorsement

• Option 1 or Option 2 indicated in UMF (Universal Mailer File)

FY10, 46.3 million First-Class Mail waste volume

Proposed Mail Handling Procedures

Mail follows normal mail processing flow until identified as Undeliverable As Addressed (UAA)

First-Class™ UAA letter mail is isolated when processed on Postal Automated Redirection System (PARS)

Proposed Mail Handling Procedures

Notification of treatment is sent to mailer via ACS™ fulfillment

Sorted to special bin for verification

Electronic Notification = Two Part Process*

1. Notification of treatment is sent to mailer via ACS™ fulfillment

2. Secure Destruction Data associated with the IMb® (Note: Name/Address data already associated with IMb), as well as event data. The event data (i.e. facility name, date and time) from CIOSS will indicate when the letter was separated for destruction 

Secure Destruction Data will be provided in a second report, not linked to ACS.

* Note: All Secure Destruction data will be made available on the Electronic Product Fulfillment (EPF) website; which is the secure website mailers currently use to get ACS data.

Proposed Verification Procedures Processing clerk manually scans all mail sorted to secure

disposal bin to validate proper sortation

Existing internal security measures, as is true with all mail

Until shredded, it is still mail

Secure Destruction Shred Standards USPS® will use industrial cross-

cut shredders

NAID Max. shred size = width .75 inch x length 2.5 inches

USPS Max. shred size will be .25 inch x 1 7/8 inch

USPS will also meet international industry standards for Security Level 3 (i.e. confidential documents that should be made illegible)

Current approach exceeds NAID and equipment can be modified if standards change

Excerpt from the NAID Auditing Criteria

“Mail sent back for destruction would be considered live mail and part of the mail stream. Therefore, the mailers would be at no greater risk for liability than they are when they drop outgoing mail off for delivery. The Postal Service is a trusted institution that is enshrined in the U.S. Constitution. See U.S. Const. Art. 1, s. 8, cl. 7; 39 U.S.C. s. 101 (The Postal Service is “a basic and fundamental service provided to the people by the Government of the United States, authorized by the Constitution, created by Act of Congress, and supported by the people.”). Therefore, it is difficult to imagine a scenario under which a company would be found liable for entrusting the Postal Service to deliver mail to its final destination, whether that be a mailbox or a shredder located on-site at a USPS facility. Further, the Federal Tort Claims Act (FTCA) includes a specific “postal matter” exception which excludes liability for any “claim arising out of the loss, miscarriage, or negligent transmission of letters or postal matter.” 28 U.S.C.  2680(b). This exception covers USPS employee misappropriation of this information. See C.D. of NYC, Inc. v. U.S. Postal Service, 157 Fed. Appx. 428 (2d. Cir. 2005) (USPS not liable for mail stolen by USPS employees).”

Carrie M. Branson, Chief Counsel - Torts, USPS Law Department

Legal Issues

After looking into this further, FISMA does not apply to the Postal Service™. We comply with it voluntarily as a general rule. However, we are not included in the definition of “agency” in the law.  The details: FISMA defines “agency” by cross-reference to the definition of “agency” in the Paperwork Reduction Act (44 USC 3502). See 44 USC 3452(a). Courts have consistently found that the Postal Service is not an “agency” under the Paperwork Reduction Act definition. See Kuzma v. USPS, 798 F.2d 29 (2nd Cir. 1986); Shane v. Buck, 658 F.Supp. 908 (D. Utah 1985), aff’d 817 F.2d 87 (10th Cir. 1987). The law clearly falls within the scope of 39 USC 410(a), which exempts the Postal Service from laws generally regulating the operation of federal agencies.  

Federal Information Security Act FISMA

Conducting weekly meetings of Postal stakeholders to develop and plan Secure Destruction Service product offering

Program Management Office in place to provide detailed structure to program

Surveyed potential suppliers capable of performing Secure Destruction Service; monthly meetings / telecoms being held

Progress

Actions When? Where?

SD Pilot Assessment 7/1/13 – 9/30/13 7 Pilot Sites

Pilot Assessment Goes Well with Decision for Full Deployment

10/30/2013 USPS HQs

If pilot successful, Nationwide Deployment Begins

11/1/201362 PARS Sites

Nationwide Deployment Complete9/30/2014 62 PARS

Sites

Mailers can use any of the approved Service Type IDs for Secure Destruction

10/1/2014 or soon thereafter Anywhere in

US

Time Table for Full Deployment

Pilot Site LocationsSecure Destruction Pilot Site Location =

Sacramento, CA PDC

Hartford, CT PDC

Nashville, TN PDC

Palatine, IL PDC

Las Vegas, NV PDC

Merrifield, VA PDC

Jacksonville, FL PDC

The Technical Side ofSecure Destruction

First-Class Mail®

First-Class Mail cannot be destroyed until it has been labeled as waste as a result of processing in PARS or CFS, and an ACS™ record generated.

If ACS cannot be generated for a piece of First-Class Mail requesting Secure Destruction, it will be returned to sender with the new address or reason for nondelivery affixed.

ACS is a requirement for Secure Destruction.

Barcode Readability If your barcode cannot be read and there is no printed

endorsement, the mail will be treated as unendorsed.

The default treatment for unendorsed First-Class Mail® is to be forwarded or returned with no additional postage paid and no separate address correction notice.

Printed Endorsement The printed endorsement takes precedence over

information provided in the STID. Therefore,

The printed endorsement must match the service you request. Failure to print any endorsement correctly could produce unintended results.

Printed Endorsement

If you choose to print an endorsement, there are only two acceptable for secure destruction pieces

Change Service Requested

Electronic Service Requested

Any other endorsement will interfere with the desired disposition of the mail.

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Change Service Requested

Option 1 All UAA mail is disposed as waste, ACS™ notice

always provided.

Option 2 Forwardable pieces forwarded, non-forwardable

pieces disposed as waste, ACS notice always provided.

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Full-Service or Basic/Non-Automation?

The full-service option has extra benefits, and has specific qualification requirements.

The basic option is for automation mail that cannot or does not meet the requirements for full-service.

Non-automation does bear IM® barcodes, and qualifies for some discounts, like carrier route and presort pricing.

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IMb Tracing™

IMb Tracing provides you with near real-time tracking info about yourFirst-Class Mail®, Periodicals, and Standard Mail®

letters and flats

It can be used on either your outgoing mail (Destination) and/or incoming reply mail (Origin)

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ACS™ Options

Traditional ACS – delivered viaElectronic Product Fulfillment (EPF) account

OneCode ACS® – delivered via EPF

Full-Service ACS – delivered via PostalOne!® after the records are associated to qualified mailpieces in the eDoc

Secure Destruction Service Type IDs

Class of MailAddress Correction

Option

Basic or Nonauto

option w/oIMb Tracing™

Basic or Nonauto

option withIMb Tracing

Full- Service w/o

IMb Tracing

Full- Service with

IMb Tracing

First-Class Mail®

Traditional ACS™ – CSR1 SD

528 527 523 525

Traditional ACS – CSR2 SD

531 526 533 532

OneCode ACS –CSR 1 SD

520 518

OneCode ACS –CSR 2 SD

315 321

Full-Service ACS –CSR 1 SD

524 522

Full-Service ACS –CSR 2 SD

335 331

SundaySunday

What You Need to Know about Unique Address Types / Non-Physical AddressJim Wilson/Adam Collinson/Michael Tate – Period 1, 12 – 1 pm

GSA and Addressing (Rules & Recommendations)Angela Lawson/Adam Collinson/Derrick Miliner – Period 4, 3:45 – 4:45 pm

MondayMonday

Keeping it Simple: ACS Services – It’s All in the Service Type IDLisa West – Period 5, 10:30 – 11:45 am

Secure and Environmentally-Friendly Destruction of Undeliverable as Addressed (UAA) MailTom Day/Lisa West – Period 8, 4:30 – 5:30 pm

TuesdayTuesday

The ROI of Great Address QualityEd Wanta/Dr. John M. Leininger – Period 10, 9:30 – 10:45 am

Understanding the Differences in the Change of Address ProgramsJim Wilson/Michael Tate – Period 13, 3:15 – 4:15 pm

Your Software is Talking, Are you Listening?Angela Lawson/Chris Lien – Period 13, 3:15 – 4:15 pm

Peer-To-Peer RoundtablesLisa West/Angela Lawson – Period 14, 4:30 – 6:00 pm

Speaker Schedule