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notice postal office opened and inspected media mail
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90 posts in this topic

8 minutes ago, s-dali said:

Comic books are not allowed to mailed media mail. Media mail was designed for libraries. The USPS does not allow periodicals to mailed by media mail.

The first screen shot is from DMM Section 173 that RMA quoted above. The scond screen shot is from the DMM section regarding periodicals, section 207. This has NOTHING to do with advertising.

 

Enforcement of the rule varies greatly.

 

dmm.jpg

dmm2.png

Media Mail (aka "Book Rate") was not established "for libraries," which you will notice by the distinction between "Media Mail" and "Library Mail" that you posted above.

Notice the language you quoted: "and that is neither mailed or required to be mailed as First-Class Mail nor entered as Periodicals, may be mailed as Media Mail or Library Mail, respectively."

See that phrase...? "...nor entered as Periodicals..." Periodicals are shipped as Second Class mail, with its own rules and requirements. These rules are for publishers and/or distributors of periodicals who send out multiple examples, tens, hundreds, thousands, or even millions of examples of the same brand new issue of said periodical. This obviously does not apply to aftermarket items, whether they are periodicals or not, since they are neither A. required to be entered as periodicals, nor B. shipped from the publisher and/or distributor.

These regulations about periodicals govern the distribution of NEW periodicals from publishers and/or distributors...not aftermarket back issues sent by individuals.

Good attempt, though!

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And, since Jane Doe shipping 15 various issues of Millie the Model is not required to enter them as Periodicals...since that governed their initial distribution, and not all subsequent mailings...then, by the USPS' own explicit rules shown above, aftermarket periodicals can be shipped Media Mail.

Yes, I understand the argument that "once a periodical, always a periodical"...but the USPS treats each mailing event as its own separate transaction, and the INTENT of the Periodical rule is positive...that is, what an item must do to qualify for the Periodical rate...rather than negative, or what DISqualifies an item. In other words: the rules that govern it as a periodical only apply to its primary distribution through the USPS...not subsequent mailings in the future.

 

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You are correct in that it was not established for libraries, it was established for educational institutes. I'll edit my original post to reflect that.

As for the rest, you make a rational argument. However, I contend that once a periodical, always a periodical is the correct way to interpret this. They do not allow newspapers or magazines, regardless of age, to be sent via media mail. Comic books are no different.

 

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6 minutes ago, s-dali said:

You are correct in that it was not established for libraries, it was established for educational institutes. I'll edit my original post to reflect that.

As for the rest, you make a rational argument. However, I contend that once a periodical, always a periodical is the correct way to interpret this. They do not allow newspapers or magazines, regardless of age, to be sent via media mail. Comic books are no different.

 

They do allow newspapers and magazines to be sent via Media Mail...it just depends on who the "they" is you're talking about, which is precisely because of the ambiguity of the regulation. Again, each mailing event is its own transaction. Second Class...the "Periodicals" mentioned...was for the cheaper distribution of new issues as they were published; it was never meant to address every subsequent mailing of those items in perpetuity.

Book Rate was established for the cheap transmission of educational materials, whether to or from educational institutions or not. The point was to foster and encourage learning. While the need for cheap bulk transmission of materials has greatly lessened with the advent of the internet, there's still a considerable demand for hard copies of all media material for educational purposes. That was its point then, and it remains its point now. The spirit of the rule...to allow Jane Doe to send a stack of 80s Star comics to a library, a school, a hospital, or another individual...remains the same. Comics books can be, and generally are, as educational as any of the other materials allowed.

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Again, all good points. I know that my interpretation is not the common one expressed by yourself and others on this forum. I have not always been s_dali. I have been reading this forum and its' threads for years. I know that nothing I can say or post here will sway anyone who is convinced they are right. Since the USPS does not directly mention used comic books, this debate will continue. I have stated my position, corrected my error and addressed a legitimate point. From there, it is all a matter of interpretation. One major question is whether or not the internal memo carries any weight. And if it does, the way they worded it can be interpreted two different ways. Even local post offices differ on the policy. Nothing will ever be decided here. Interpret the rules the way you wish, but don't be surprised when someone disagrees.

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34 minutes ago, s-dali said:

Again, all good points. I know that my interpretation is not the common one expressed by yourself and others on this forum. I have not always been s_dali. I have been reading this forum and its' threads for years. I know that nothing I can say or post here will sway anyone who is convinced they are right. Since the USPS does not directly mention used comic books, this debate will continue. I have stated my position, corrected my error and addressed a legitimate point. From there, it is all a matter of interpretation. One major question is whether or not the internal memo carries any weight. And if it does, the way they worded it can be interpreted two different ways. Even local post offices differ on the policy. Nothing will ever be decided here. Interpret the rules the way you wish, but don't be surprised when someone disagrees.

more importantly, don't be surprised if the post office disagrees.

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3 minutes ago, s-dali said:

Again, all good points. I know that my interpretation is not the common one expressed by yourself and others on this forum. I have not always been s_dali. I have been reading this forum and its' threads for years. I know that nothing I can say or post here will sway anyone who is convinced they are right. Since the USPS does not directly mention used comic books, this debate will continue. I have stated my position, corrected my error and addressed a legitimate point. From there, it is all a matter of interpretation. One major question is whether or not the internal memo carries any weight. And if it does, the way they worded it can be interpreted two different ways. Even local post offices differ on the policy. Nothing will ever be decided here. Interpret the rules the way you wish, but don't be surprised when someone disagrees.

It's true; nothing anyone can say will sway anyone who is "convinced they are right", which includes you, as well, does it not? I haven't been surprised when someone disagrees since maybe high school...? It doesn't matter, then, if there's disagreement. Anyone can disagree with anything. Disagreement in and of itself is of no value. What matters is the strength of the argument

I make the best argument I can, as should everyone. If people are persuaded, great. If they are not, great. If you make a good point, if you make a point that hadn't been considered, only a fool would stubbornly stick to his position in light of new evidence that changes the parameters of the discussion...but there must be new evidence to consider, not the same arguments rehashed and restated (which is the usual status on message boards.) The people who say "the USPS does not allow comic books to be shipped via Media Mail" are the ones taking a position that is actually open to interpretation. But there are some things which are not open to interpretation, and the supremacy of the DMM is one of those things. If it's in the DMM, it's gold; if it's not, it is totally irrelevant. That's how governmental agencies operate.

The beauty of this particular situation is clear: if one doesn't agree, there's nothing requiring them to use the service. I've spent a considerable amount of time researching this particular issue. As you yourself say, I've made a rational argument. Until and unless the DMM is updated, it will continue to come down to interpretation.

 

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39 minutes ago, RockMyAmadeus said:

It's true; nothing anyone can say will sway anyone who is "convinced they are right", which includes you, as well, does it not? 

 

Indeed it does. After all, my statement was meant as positive, meaning that anyone who believes they are right cannot be swayed. I, obviously, believe that I am right, therefore I cannot be swayed. :)  I, too, have spent considerable time researching this subject, I just happened to reach a different conclusion than you did. This situation is not unique. Just look at the debate between creationists and evolutionists over fossils. Both sides have the same evidence, yet they have two completely different interpretations. And those debates are among highly learned men and women, they are hardly ignorant or stupid. 

 

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It took me a bit to find this link. This is from littleblue.usps.gov. It is a site that is used by USPS employees and is overseen by the USPS. This is a list that shows that comic books are not allowed and the section of the DMM that they use. If you look at the chart, magazines are not allowed regardless of age. Now, you might say, correctly, that the DMM is the final authority. However, if a website populated by USPS employees interprets something in the DMM that is unclear, I contend that it does carry weight. If each post office had the manpower to open every media mail package, I think you'd see this policy enforced a lot more.

https://liteblue.usps.gov/news/link/2013/04apr/Media-Mail-Guidelines.htm

 

 

littleblue.jpg

Edited by s-dali
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2 hours ago, s-dali said:

It took me a bit to find this link. This is from littleblue.usps.gov. It is a site that is used by USPS employees and is overseen by the USPS. This is a list that shows that comic books are not allowed and the section of the DMM that they use. If you look at the chart, magazines are not allowed regardless of age. Now, you might say, correctly, that the DMM is the final authority. However, if a website populated by USPS employees interprets something in the DMM that is unclear, I contend that it does carry weight. If each post office had the manpower to open every media mail package, I think you'd see this policy enforced a lot more.

https://liteblue.usps.gov/news/link/2013/04apr/Media-Mail-Guidelines.htm

 

 

littleblue.jpg

And again, I will argue that this list...and the "official notice" discussed earlier...is someone's misunderstanding of Media Mail. This chart, too, has been posted before, and it has been debunked as well. They are someone's interpretations...and bad ones at that...of the DMM. Look at the contradiction right there on the page between "comic books", "Graphic novels", and "coloring books." The reason they give for not allowing coloring books is that it doesn't "consist wholly of reading matter." But what is "reading matter"? Films...which generally contain NO reading matter...are perfectly allowed, are they not? The person/s who wrote that chart interprets "reading matter" to be nothing but words on a page. 

Now look at the justification for comic books: "Predominantly pictures." Compare that to "graphic novels" (which the AE that Jerkfro mentioned is)...aren't "graphic novels" "predominantly pictures"...? Of course. But, since they contain the magic phrase: "no advertising"...they're allowed? So which is it? Are pictures the problem, or aren't they? Is advertising the problem or not?

And that is why the above chart carries zero regulatory weight: it is self-contradictory and contradicts the DMM. Whoever wrote it understands neither the spirit, nor the letter, of the regulation, and why it exists in the first place. The "no advertising" restriction was placed so that workers could easily identify commercial distributions of new periodicals that were a violation of Second Class rules. It wasn't meant to be an end-all, be-all rule for any item containing advertising, or what was once advertising, forever and ever, amen.

Make no mistake: my argument is theoretical, not practical. Obviously, no one can go in and say "but the DMM says....!" and expect to get a bureaucrat with an opposing opinion to listen. Obviously, there are workers within the USPS who take this chart, and the "official notice" posted prior, as set in stone rule.

But the amount of change that happens if no one says anything is exactly none. And...in the admittedly unlikely event that someone were to challenge the USPS, all of these little contradictions would be completely destroyed. And...if the USPS had the manpower to enforce this rule, I imagine you'd get a lot more people complaining about it until it was officially and finally addressed in the DMM, one way or another, instead of this limbo state we've been in since the dawn of the internet.

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32 minutes ago, RockMyAmadeus said:

And again, I will argue that this list...and the "official notice" discussed earlier...is someone's misunderstanding of Media Mail. This chart, too, has been posted before, and it has been debunked as well. They are someone's interpretations...and bad ones at that...of the DMM. 

I have no idea how you can "debunk" an interpretation. Debunk means that you expose the falseness of a statement. That chart is an interpretation. As for the rest of your statement, you just reminded me of why I don't post. To think that a bunch of comic book collectors are in a better position to interpret USPS rules and regulations than actual USPS workers are, is beyond my comprehension. The level of self-righteousness and arrogance is strong on these pages. I think I'll just wait a few more years before I comment on anything else here.

 

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You can argue it forever and never come to any conclusion that is 100% guaranteed to be correct when it comes to media mail usage. The real issue here is what we as buyers and sellers should do when sending comics if we care about the hobby.

Bottom line for me is simply this-- media mail is:

1 - SLOW

2 - often Handled with less care

3 - occasionally opened and inspected, possibly changing the initial packaging and possibly not sealed again

4 - often times saves very little money compared to first class mail - especially when sending one or two books

IMO - Those are four excellent reasons NOT to use this service when sending someone a collectible because I personally don't want people to send me a package this way and will very rarely buy a book from a seller who states they intend to use this method of shipping. Sending me 1 to 3 comic books can be accomplished using first class mail, sandwiched with two sturdy pieces of cardboard. More expensive books should be sent in a box via priority mail. The reasons are simple-- they limit the impacts of problem areas 1 through 4.

Why give the post office a reason to open your package ever? It simply is not worth it.

 

ps- IN the above statements, I am only referring to shipping traditional comic books. TPBs and other forms that have no advertising but are also significantly heavy are one exception that seems reasonable for media mail usage preferably in strong boxers with excellent packaging.

Edited by 01TheDude
added the ps disclaimer
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2 hours ago, 01TheDude said:

The real issue here is what we as buyers and sellers should do when sending comics if we care about the hobby.

Why give the post office a reason to open your package ever? It simply is not worth it.

 

 

+1

 

I don't understand how people can be condition-conscious but have no problem using MM.

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5 hours ago, 01TheDude said:

ps- IN the above statements, I am only referring to shipping traditional comic books. TPBs and other forms that have no advertising but are also significantly heavy are one exception that seems reasonable for media mail usage preferably in strong boxers with excellent packaging.

What about shipping old OSPGs via Media Mail?

Here at the library we shelve in the Reference section (rightly so) and not in the YA or Adult Graphic Novel section. They don’t contain sequential story-telling artwork. 

However, they are full of advertisements, many of which are still “live”. 

And for the postal employee who’s not giving his full attention, it does have the words “comic book” in giant letters on the front cover along with a cartoon picture. 

So while I agree that the inspection component alone of Media Mail makes it unexceptionable shipping for collectible comics, I too think it would be nice if USPS made some more definitive clarifications as to what is allowed to ship Media Mail. 

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12 hours ago, s-dali said:

I have no idea how you can "debunk" an interpretation. Debunk means that you expose the falseness of a statement. That chart is an interpretation. As for the rest of your statement, you just reminded me of why I don't post. To think that a bunch of comic book collectors are in a better position to interpret USPS rules and regulations than actual USPS workers are, is beyond my comprehension. The level of self-righteousness and arrogance is strong on these pages. I think I'll just wait a few more years before I comment on anything else here.

 

I don't understand why you seem upset. I thought this was a great discussion and was enjoying reading it. Both of you guys did a great job articulating your points.

An interpretation can still be false and debunked. I'll use fossils as an example since you invoked them in a previous comment:

Creationists are wrong on their interpretation of fossils and easily debunked: Fossils are only one evidence of evolution that isn't even required to verify common descent. It's just a bonus. When one looks at all of the available evidence for common descent, the only way to reject it is to claim conspiracy.

Edited by Skeptic_Kepp
OCD
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21 hours ago, The Lions Den said:
On 8/3/2018 at 9:00 AM, Jerkfro said:

I grab cardboard from work and use one of those old school guillotine paper cutters to cut them up. 

I thought I was the only one who still did this. (It's also a good way to remove fingers that you don't really need...) lol

Only two so far!

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1 minute ago, Jerkfro said:
21 hours ago, The Lions Den said:
On 8/3/2018 at 6:00 AM, Jerkfro said:

I grab cardboard from work and use one of those old school guillotine paper cutters to cut them up. 

I thought I was the only one who still did this. (It's also a good way to remove fingers that you don't really need...) lol

Only two so far!

I do the same.  I have a cutter from when I used to have my own darkroom.  The nice thing is you can very precisely cut the cardboard.  This is important if you want to fit a comic book sandwiched between 8 sheets of cardboard (depending on the thickness) into a USPS Legal Flat Rate Envelope.

Looks like this.

acJxZpF.jpg

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@Skeptic_Kepp - I got upset last night by the wording of RMA's response. He stated that the chart on the blueline website was a bad interpretation of the DMM rules and regulations and that it had been debunked, meaning that it had been proven to be false. How?? How can you PROVE that the chart is false? You can't!!! Just like you can't prove that it is entirely true. To do so would take clear and precise wording in the DMM or clear and precise Customer Support Rulings. We do not have that in regards to the subject of mailing comic books via media mail. Plus, taking what he stated to the next logical step, if the interpretation on an USPS associated site is a bad interpretation and wrong, so is every other interpretation. To me, what he stated was a sign of debating with a very closed minded individual. I have better things to do than waste my time debating with such an individual.

My fossil example was a bad one. In my mind, this is more like a court case. Courts are there to interpret the law as it applies to individual cases. In many instances, the laws are cut and dried. In other instance, if you disagree with the interpretation, you can appeal a case. It can go up the chain of courts until it reaches the Supreme Court,  which has the final say in interpreting American laws. In this case. the Supreme Court would be the Postmaster General or perhaps a committee, whoever it is that oversees the rules and regulations of the USPS. The blueline site is equivalent, in my mind, to a lower court, perhaps even an appeals court. It is composed of USPS employees whose jobs are dictated by the DMM. These are knowledgeable people, or they should be, when it comes to the inner workings of the USPS. At the very least, they are more knowledgeable about every aspect of the USPS then the average citizen. For all we can tell, that chart could have been made up by a committee or an individual. It may have originated in an USPS office in Washington, DC. But it doesn't matter, to dismiss such a reference so flippantly comes across as arrogant and obnoxious. I hope that helps to explain why I was upset last night.

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12 hours ago, s-dali said:

I have no idea how you can "debunk" an interpretation. 

 

You can't. More importantly, no one tried. You've invented something that no one did, and then argued against it. That's a straw man argument.

The validity of that chart was what was debunked, and the how and why was explained above. 

12 hours ago, s-dali said:

Debunk means that you expose the falseness of a statement. That chart is an interpretation.

Yes, that chart is an interpretation, but it also contains contradictions, as pointed out above. Interpretations can't be debunked. Contradictions can.

12 hours ago, s-dali said:

As for the rest of your statement, you just reminded me of why I don't post. To think that a bunch of comic book collectors are in a better position to interpret USPS rules and regulations than actual USPS workers are, is beyond my comprehension. 

This is an excellent example of the appeal to authority fallacy, which is, in my opinion, the single most common logical fallacy used in discussion today. What makes "a bunch of comic book collectors" (a rather dismissive characterization, I might add) intrinsically less qualified than "actual USPS workers" about how the USPS works? 

The answer, of course, is nothing. Just because someone works for the USPS, that doesn't automatically mean that their understanding of USPS rules and regulations is therefore superior to someone who doesn't work for the USPS, merely on the basis of their employment. It's a fallacy, an appeal to authority. One's status, one's position, one's employment doesn't automatically confer knowledge and wisdom on anyone, doesn't automatically make them more qualified than someone not in that position...it merely makes them more likely to know the answers (and sometimes, not even that.) 

The facts are what they are. The facts do not care if you're the Postmaster General, the average mail carrier, or Joe Blow on the street. There are plenty of people who don't work for the USPS who know a great deal about how it operates. And there are plenty of people who work for the USPS who know substantially less than the first group. 

Not only should that not be beyond anyone's comprehension, it should be taken for granted. 

13 hours ago, s-dali said:

The level of self-righteousness and arrogance is strong on these pages. I think I'll just wait a few more years before I comment on anything else here.

U mad bro...?

What is "self-righteous and arrogant" about presenting a well crafted argument...? If you have a rebuttal, post it. I'm sure others have appreciated your point of view. Why the need for this sturm und drang?

On a personal note, if you're going to get so upset about people disagreeing with you, and disagreeing in a manner in which you do not approve, to the point where you toss out accusations of "self-righteousness and arrogance", just because someone doesn't agree with you (which reaction, by the way, you telegraphed a few posts earlier...you can ALWAYS see the signs that someone is taking the discussion personally)...then yes, perhaps it would be best for you to refrain from posting.

"Not only do you not agree with me, but you insist on disagreeing with me!" = "self-righteousness and arrogance"...?

Who, really, does that apply to here....?

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