It has come to our attention that USPS is still in the process of putting together lists of offices that they intend to perform counts and inspections on starting in September 2025.
We have also heard that they will be sending out the notifications to the local Union reps in accordance with Handbook M-39, Section 211.2 prior to conducting the annual unit and route reviews required under section 211.1.
With that in mind we find it very hard to believe that they will be able to complete all of the requirements of Handbook M-39, Sections 211.1 through Section 217 within the next 5 weeks or so before the actual counts start. Below are some of the things I think we should relay to our grievance handlers prior to the start of these inspections:
Handbook M-39, Sections 211.1 -211.4:
As you can see, Section 211.1 (Route and unit reviews) comes before 211.2 (Notification of selected count period). The purpose of route and unit review is, at a minimum, to review the items in Section 214 (See attached below) to determine the number of routes to be inspected. The results of the review of at least those items in Section 214 have to be provided to NALC President, designee, and the regular carriers serving the routes. It is NOT sufficient for management to simply run a Workhour/Workload report from DOIS for the last year and share it with the Union and carriers., though this often what they do. When investigating potential grievances concerning the route and unit reviews, grievance handlers should request the actual information that management reviewed and compare what is provided to the list of minimum items in Section 214 below. We also may want to interview those members of management that performed these reviews and specifically ask them, on the record, about each of the listed items. See 214 Below:
Management also has the responsibility, under Section 213, to review certain carrier control forms prior to the start of the count and inspection. These items are listed below and should be reviewed 4 to 5 weeks before the count starts, which in some cases is NOW. As with the route and unit reviews discussed above, grievance handlers should request these forms and if necessary, interview the managers that reviewed them. See below:
All too often, the count starts, the edit books are wrong, which impacts the accuracy of territory moves in adjustment, the route books aren’t up to date (1564-A and 1564-B), case labels are no good, the 1840-B times don’t include any auxiliary assistance provided, and the route examiners start deducting time in the office and on the street due to the failure to properly review the data before the count starts. Section 214 very clearly states: “All operations at the delivery units should be reviewed and any unsatisfactory conditions should be corrected before the count is commenced.”
Management also has the responsibility to ensure the Dry Run training is conducted within 21 days of the start of the count. All letter carriers performing letter carrier duties on any routes that are being inspected must receive this instruction on properly completing forms before the count starts. This includes CCA’s, PTF’s and all fulltime letter carrier positions. Grievance handlers should request a list of all those who participated in the Dry Run training to ensure compliance. We also may request TACS Employee Everything reports to confirm carriers were on the clock and performed the training. See Section 217 below:
In most places, programmed annual leave bidding for 2025 was conducted at the end of 2024. This is problematic for management in that Section 211.4 states that: “to the extent possible, planning for that inspection should normally be completed before annual leave bidding begins. This will enable management to exclude from leave charts the week selected for count and inspection.” Carriers should not be denied programmed annual leave due to managements late notification of an inspection. Accordingly, violations of this section should be included in our grievances. (See 211.4 above)
The posting of the count and inspection schedule must also be done prior to the start of the count and inspection. Management must also give at least 1 day notice of any changes. See Section 215 below.
These are some of major items our grievance handlers need to look at before the count and inspection even starts. You can see management has numerous responsibilities that they must fulfill prior to the count starting. Given that in most areas they haven’t decided who they want to inspect and the short time before counts will commence, I anticipate that the violations will start piling up rather quickly. It is a ton of information to request and a lot of steward time to be spent, but we must remain dedicated to ensuring a fair and representative evaluation of out letter carrier routes is performed.
I wanted to get this out as we are close to the start of Fall inspections and management is already behind in their requirements. I encourage all of our grievance handlers to read and become familiar with the resources available to us in enforcing our contractual rights when it comes to route inspections. Resources are available at nalc.org.
