Monthly Archives: August 2013

Will Darrell Issa Save the Post Office? Or Put Another Nail in the Coffin?

Early last week, Darrell Issa, a Representative of California and chairman of the the US House Oversight and Government Reform, signed off on H.R. 2748, the Postal Reform Act of 2013 which is designed to bring the United States Postal Service (USPS) to financial solvency with cost-cutting reforms and innovative new sources of revenue.

SI has been asking if the US Post Office can be fixed for a while now, with its most recent post on the subject last summer (Source). Given that the USPS has more debt than 50+ countries have capita, fixing it is a tall order – especially when the US needs to identify immediate savings of almost 20 Billion plus (as it keeps bleeding red with losses of 15.9 Billion in 2012 and 3.2 Billion in the first two quarters of 2013).

Key points of the plan, as summarized in this Logistics Management article, include:

  • moving from door to curbside delivery and neighbourhood boxes, which could save 4 Billion annually,
  • ensuring small and rural post offices are protected from a disproportionate number of closures,
  • creating a Chief Innovation Officer,
  • protecting existing collective bargaining agreements,
  • recalculating projected liabilities for employee pensions, and
  • offering additional relief from retiree health care benefit payments.

While SI has to say it likes the first and third options, that’s not going to be enough to generate the savings required giving that costs are going to keep rising.

SI agrees with Rob Martinez, President and CEO of Shipware Systems Corp, cited in the Logistics Management article, who noted that a comprehensive plan that addresses multiple options is required if the USPS is to become solvent again. However, SI’s approach, which differs from Mr. Martinez’s, would involve the following:

  • maximization of neighbourhood box and curbside deliveries,
  • an immediate end to Saturday mail delivery,
  • global restructuring and consolidation of postal facilities until all are at least break-even*,
  • freedom to revise operational practices to take advantage of savings identified by Procurement and new sources of revenue identified by Marketing and Innovation, and
  • freedom to enter into co-opetition agreements with the major private delivery companies to share resources and routes, for both long-haul and last-mile deliveries, in ways that save both parties money.

SI does not agree with eliminating the pension prepayment mandate, freeing up a percentage of pension funds to ensure ongoing solvency, or cutting contributions to retiree health benefits. Not sufficiently funding these payment obligations is what got the USPS, and a whole bunch of other public and private organizations, into this mess in the first place. (However, SI fully supports a careful recalculation of the unfunded liability to make sure the payments do not exceed what is required.) Plus, it’s the USPS after all. Congress, who dumbly vetoed elimination of Saturday mail delivery, isn’t going to stop lending the USPS money until they find a way out of this mess, so it’s not like the USPS has to worry about bankruptcy. The USPS has to get it right, not exacerbate the problem.

And in SI’s view, the current plan will not save the post office and may even put a nail or two into the coffin because every provision except the provision to move to neighbourhood boxes and curbside delivery is likely to increase costs in the long run.


* SI agrees that every town needs a postal facility and that anyone in a rural area should have a post office within a reasonable distance, but doesn’t agree that this means that existing facilities stay open. They may need to be reduced in capacity and change locations. For example, here in Canada, many locations are sublet in retail establishments, and drug stores in particular (which are open long hours). These micro locations can be staffed by one person and cost next to nothing.

A Customs Audit is Coming Your Way – Are You Ready?

As per this recent post over on the C.H. Robinson blog, the U.S. Customs and Border Protection (CBP) is stepping up enforcement of customs compliance. It’s not just looking for fraud, but for poor record-keeping, mistakes, and uncorrected discrepancies that will allow up to impose fines of up to $10,000, penalties of up to 8 times the value of the loss of duty on dutiable items, and penalties of up to 80% of the value of non-dutiable items which allow the CBP, and the U.S. Government, to fill its coffers at your expense. Just like ignorance of the law is no excuse, neither is an innocent mistake.

And while you can’t prevent an audit, you can prevent a fine and a penalty by making sure you don’t make any of the nine-common trade-related errors the CBP will get you on and, in a few cases, taking extra steps to limit what can be held against you. To minimize fines and penalties,

  • Report Manufacturing Assists which are dutiable (at cost).
  • Have a system and process in place to verify the mainfest immediately after the ship is loaded.
    If there are additional, missing, or damaged items, and the price is modified, the price you are actually going to pay needs to be reported.
  • Be sure not to include dutiable costs! While you will be refunded duty overpayments, you can also be fined $10,000 for a record-keeping error!
  • Don’t screw up the country of origin. It’s not necessarily the exporting country. It may ship from China, but it could be manufactured in Myanmar and Vietnam.
  • Get the HTS code right. Hire a consultant or acquire an import trade tool if you have to, because if you get this wrong, here’s where the 8X penalty comes into play!
  • If claiming Free Trade, make sure you have the arguments, documentation, and, if they exist, previous determinations or rulings to back it up.
  • If you are re-importing goods into the US (HTS 9801 & 9802), be sure to have tangible proof of US manufacturing and a full chain of custody that demonstrates no advance while abroad.
  • Don’t screw up the amounts claimed in a related-party transaction.
    Just because you trade goods for $1 does not mean this is the value you can claim when calculating duty.
  • Keep exactly 5 years of records. You have to keep five years, or get fined, but if you have more than 5 years, you are just giving the CBP more records to go through to find problems.

Will this completely eliminate your risk? No, but it will greatly reduce it!