Few apartment owners or property managers realize that it’s not possible to replace their mailboxes by searching online for equipment [that looks like what’s there now] and ordering and installing it. This is because the mailboxes installed before 1999 are probably illegal, not security-compliant, not-repairable and may even be owned by the Post Office that doesn’t sell them anymore. This is because in April 2012, the Postal Operations Manual PO 631.441 became effective and the USPS simultaneously got out of the mailbox sale and installation business.
POM 631.441 – Delivery Requirements
“[Only] CBUs and USPS STD 4C equipment may be approved for use at one or more central delivery points in a residential housing community”.
Combine this with the facts that 1) apartment mailbox upgrade projects are notorious for seven legal risks 2) operations complexity and 3) it’s sometimes very difficult to find the correct decision maker at the Post Office. As many contractors, property managers, apartment owners and homeowners have learned – mistakes can be both embarrassing and expensive.
MISTAKE #1 – Failure to Allow For “Reasonable Accommodation” ADA Requests.
This mistake is extra tricky because less than half of Post Masters are not even aware of it – but then again, the Post Master is NOT an ADA compliance watchdog. Like everything with a mailbox upgrade, this job falls to the property manager and the apartment owner. The issue here is to recognize that there is an inherent conflict between upgrading to one of the two “security-compliant” upgrade mailboxes, [i.e., Spec F CBUs and 4C STD Horizontal mailboxes] and ADA compliant mail doors which must be below the 48” ADA high reach spec for a person in a wheelchair. Since the new security compliant mailboxes are taller and narrower than the old mailboxes, a good portion of the new mail doors [usually about half] are above the ADA high reach spec of 48” AFF and are thus non-ADA Compliant. So when an infirmed or elderly homeowner makes a “reasonable accommodation request” for a lower [ADA compliant] mailbox, the apartment management will be unable to comply unless there are ADA Reserve doors below the 48” line. With a spare “ADA Reserve” door, solving this problem is simply accomplished by moving the inside address sticker [inside the mailbox] from the higher to lower mail door] and swapping the mail door keys. When the ADA homeowner moves, the process is reversed so that there is [hopefully] always an inventory of “ADA Reserve Doors” without having to go through a mail pull/lock pull/mail downtime cycle for mail door repositioning. A case in point is a recent project where the provisioning of “ADA Reserve Doors” was able to immediately handle a request from a [short] and disabled tenant for a lower mailbox. Since the apartment owners did not even know that they had been protected against this risk, they were EXTRA happy when they learned about it. The “best practice” here is to make sure your contractor configures your upgrade to prevent this problem.
Mistake #2 – Not getting USPS AMS Compliance Approval
The Address Management System [AMS] is a separate division of the USPS that controls the “Master USPS Address Database” that drives mail sorting at one of the 21 centralized USPS Network Distribution Centers [NDCs] that sorts mail for the local carrier or sends it to the next NDC. The NDCs are what all USPS employees collectively call “The Plant” although there are 21 of them. To understand the importance of “The Plant”, each night, the mail from all post offices [in 21 groups of zip codes] have their mail trucked to “The Plant” where it is sorted by the overnight staff and returned the next morning in trays for carrier distribution in a sequence supposedly related to mail carrier productivity. This is often outdated because AMS has not upgraded the Master USPS data base for the USPS-approved sorting sequence which is supposed to be “top to bottom left to right – numerically-ascending” for centralized delivery locations [for single stop centralized mail delivery units] such as the two current USPS security compliant specifications – Spec F and STD 4C. So even though a Postal Supervisor has approved a mailbox upgrade plan, [written letter or not], it is very important that your contractor actually checks the AMS sorting sequence and includes this as an attachment to the USPS Approval Letter he/she will get for you from the Post Master [or his designated Supervisor] prior to the start of the project. If you don’t do this, the carrier will simply not start delivery to your new mailboxes and you’ll have a real mess on your hands. This is especially true for apartments using NDCBUs that are on courts, cul de sacs, or terraces where an old sorting sequence called “stop and loop”, is still in the AMS database. We know of instances where the new CBUs were numbered according to the current “top to bottom left to right numerically-ascending” rule only to learn upon installation that the carrier had stopped delivery because the sorting sequence conformed to the old “Odd-ascending, even descending” [aka park and loop] Master Database sequencing where the carrier would stop at the entry to a cul de sac and hand deliver the odd mail up the left hand side of the street [1, 3, 5, 7 etc. and then come back down the right hand side of the street 10, 8, 6, 4, etc. In this case it took another 10 days until the error was corrected. Since the Post Office itself won’t always catch these problems, the “best practice” is to make sure your contractor checks for correctness and assures you in the contract that it will.
MISTAKE #3 – Ineffective Complex Multi-Entity Project Management
Most property managers and apartment owners prefer a central project management point and unless a knowledgeable professional is retained for mailbox project, the job falls to the property manager or apartment owner. Since matrix management first evolved in the 1960s, complex projects require a multi-entity project team to do exactly the right thing at the right time or things can go wrong. The problem is that the tasks cut across three mail organizations 1) the USPS, 2) the apartment owner, 3) the property management firm and 4) the contractor and multi-entity project manager that your contractor should provide by contract.
To make matters more complicated, the first of these four entities – the USPS, has four separate areas that require approval and action to execute the schedule a) USPS Post Master and/or approving supervisors, b) the Address Management System [AMS] c) the mail carrier, and d) the master lock installer. The second of these entities is the apartment management which involves a) apartment ownership, b) property managers, and c) homeowners, many of whom may have questions and opinions on the project and a separate group with the USPS known as the Address Management System or AMS. Since ultimately property owners are responsible for ADA Compliance, USPS Compliance, AMS Compliance, homeowner notification, key distribution to homeowners, spare key and lock secure storage, most apartment owners and property managers prefer hiring an experienced contractor which is the third of the entities required for a successful project. The best practice to prevent this problem is to assign ONE single entity to be operationally and legally responsible that all the risks are hedged and that the maximum real estate value is realized for apartment owners.
MISTAKE #4 – Failure to Update Mailboxes
Unless upgraded in the last 16 – 20 years, the old pedestal mounted [on the sidewalk] NDCBUs, or recessed mounted 4B or vertical mailboxes, are NOT going to be compliant with current USPS security specifications and this fact alone leaves the association exposed to negligence actions should a mail theft develop and become part of a homeowner’s identity theft which can have very expensive downsides in state court. Although most apartment owners and property managers are risk adverse, few appreciate the implications of the USPS discontinuing its upgrade of old mailboxes while at the same time disallowing others to repair old mailboxes due to their ease of break-ins.
In 2003 and 2006, the USPS published the Spec F and STD 4C Horizontal mailboxes which obsoleted its own NDCBUs that we see today all over the place with the USPS stickers on the side. Most owners and managers may think the Post Office owns the mailboxes and they technically do, but ignorance of the law is no excuse. The legal fact is that the owner has an obligation to protect against mail theft and to upgrade old, out-of-spec mailboxes to reduce negligence tort actions against it in cases of identity theft.
MISTAKE #5 – Not Understanding the Real Estate Value of an Upgrade
Many apartments in the Bay Area are worth multiple millions of dollars and old mailboxes may be the first thing a prospective tenant or potential buyer sees upon entering the property. Consider this quote from a recent case history – “Everything with the mailbox upgrade went perfectly! And everything looks amazing! Thank you for everything and all of your help”. Just as the recent boom “real estate staging” has become so popular for home real estate sales – the cam can apply to apartment rental or sales – especially with mailboxes. Since the purpose of “staging” is to make the real estate transaction [rent or sell] happen as quickly as possible at the highest price, this mistake is all too common with apartment owners looking at cost instead of ROI. Since mailboxes are often the first thing a prospective tenant or purchaser sees upon entering the property, the best practice” here is to get a quote and then work out the ROI for either increased rent OR increased apartment value.
Mailbox upgrades are complicated and widely misunderstood legally and operationally. We discuss only the top five mistakes here. But we want apartment owners and property managers to be aware of five more mistakes which we simply list here: 6) failing to use a borescope to survey recessed upgrades for adequate depth of replacement units, 7) not considering B Doors [for improved package flow and security], 8) violating the ADA high reach spec for NDCBUs on a curb, 9) inadequate contractor warranties and 10) failing to get written USPS agreement to the mail pull/lock pull/mail downtime cycle for mail door repositioning and to protect against the rogue postal employee problem. To avoiding these and other mistakes, AND to take advantage of the improved real estate value or rental income of an upgrade, it is important to make sure your selected contractor has the expertise to keep an apartment building and its owners and managers on its successful path and to prevent future problems.
James [Jim] McBurney, MA, MBA is the Marketing and Project Manager for Cascade Building Inc., a California contractor specializing in apartment and HOA mailbox upgrades in California. The company’s free consultations and proposals use industry and USPS best practices that seek to minimize [seven] legal risks and project complexity and often result in “perfect projects” as evidenced by its many apartment owner and property manager references. All Rights Reserved.