Canada Gazette, Part I, Volume 147, Number 51: Regulations Amending the Mail Receptacles Regulations
December 21, 2013
Canada Post Corporation Act
Canada Post Corporation
REGULATORY IMPACT ANALYSIS STATEMENT
(This statement is not part of the Regulations.)
Rural mail boxes that are not securely attached to a fixed post and whose bottoms are less than 105 cm above the ground can impede safe and efficient access by postal employees. In order to ensure the safe and efficient delivery of mail to rural mail boxes, minor changes are needed to the rural mail box specifications contained in the Mail Receptacles Regulations (the Regulations).
The Regulations also provide specifications for mail box assemblies as well as conditions and specifications for parcel compartment units in apartment buildings and office complexes. There is a limited number of mail box assemblies on the market that meet the current specifications. Most of these assemblies provide very little room for small parcels; thus, if a parcel cannot be delivered, the customer will need to pick it up at a post office. Currently, the installation of parcel compartment units is not mandatory, but if such units are installed, they must be located adjacent to the mail box assembly inside the building. Not all buildings have sufficient space in their lobbies for parcel units.
Rural mail boxes
The Canada Post Corporation provides mail delivery service to approximately 740 000 rural mail boxes across the country. Delivery to rural route mail boxes has been an integral part of rural mail delivery for decades. Today, rural addresses represent approximately 5% of the 15 million Canadian addresses.
Canada Post has 4 500 rural and suburban mail carriers (RSMCs) who deliver mail to rural mail boxes. In some cases the vehicles they use are supplied by the Corporation, while in other instances they are supplied by the delivery employee. There can be a significant difference between the window clearance/height of a small sedan and that of a crossover vehicle, although both are built on an automobile frame. The difference can be even greater with sport utility vehicles (SUVs) that are built on truck chassis. Currently, more than 80% of existing vehicles in use by RSMCs have a window clearance of over one metre.
The Regulations now stipulate that the bottom of a rural mail box must be approximately 100 cm above the roadway. This requirement is difficult to standardize as the measurement is only approximate and road surfaces can be of varying heights and grades depending on location, surface quality, age, condition and other factors.
The Canada Post Corporation has both a moral and a legal obligation to ensure the safety of its employees while also providing mail delivery service to all Canadians in a financially sustainable manner. Unique employee body types, varying vehicle designs and heights, as well as the varying height and type of rural mail boxes can make the delivery of mail in a safe manner challenging for Canada Post delivery employees. Over time, as vehicle dimensions and designs have changed, some delivery employees have raised ergonomic concerns related to having to reach or reposition themselves within their vehicles to serve rural mail boxes through the passenger-side window. In particular, these factors may cause delivery employees to make awkward movements and may increase the risk of repetitive strain injuries.
Currently, the Regulations require the boxes to be securely attached to either a fixed post or a cantilever arm. In many instances, the cantilever arms are intentionally not fixed, so that the mail boxes can withstand or survive the work of snowplows. However, a box that has been dislodged from its fixed location is physically difficult, and in some cases dangerous, to service. In some cases, the cantilever arm positions the mail box too close to the road, which makes it difficult for the delivery agent to deliver the mail without obstructing traffic. Preventing the use of mail boxes with cantilever arms would allow more efficient access to the mail box by delivery employees and reduce the risk of personal injury.
In conjunction with the regulatory amendments, Canada Post is working to address the ergonomic concerns through two important initiatives. First, a reaching device has been developed to help reduce the risk of injury. The device is a job aid for employees to use when delivering mail through the passenger-side window of a vehicle into a rural mail box. This ergonomic tool has been designed to allow RSMCs to use the tool while remaining seated in the driver’s seat with their seatbelt on. The device serves to extend the employees’ reach, allowing them to both deposit and retrieve mail from rural mail boxes without needing to either reposition themselves or perform extended stretches and awkward movements. Second, right-hand drive vehicles are being introduced where it is feasible to do so. These vehicles provide easier access to rural mail boxes by delivery employees. When fully deployed, over 1 000 right-hand drive vehicles will be in use to provide mail service in suburban and rural Canada.
Canada Post is proposing minor modifications to the Mail Receptacles Regulations in order to reduce variation in mail box heights, optimize the introduction and use of the reaching device and right-hand drive vehicles and compensate for differences in vehicle heights, thereby encouraging safer conditions for delivery employees. The proposal would require boxes to be securely fastened to a fixed post and specify the required height. Consequently, some rural mail boxes may have to be raised by 5 to 15 cm, measured from the ground immediately below the box.
Regarding the proposed changes to the mail box assemblies, it is anticipated that the new specifications would facilitate delivery and provide addressees with more convenient and secure access to their parcels.
The proposed Regulations would
- (a) require rural mail boxes to be securely fastened to a fixed post only;
- (b) stipulate that the distance between the bottom of a rural mail box and the ground immediately below it must be at least 105 but not more than 115 cm;
- (c) update the dimensional specifications for mail and parcel boxes utilized for apartment buildings and office complexes; and
- (d) permit the installation of parcel boxes either inside or outside apartment buildings and office complexes.
Benefits and costs
Canada Post estimates that approximately 15 000 to 20 000 rural mail boxes may require modifications as a result of the proposed amendments. Of these, approximately 90% will require modifications to their height. These modifications are expected to be minor and could be made at no cost or with very minimal cost to the customer.
The use of mail boxes on cantilever arms is not widespread, most of the few remaining boxes of this type having been removed already as a result of the rural safety review conducted over the past five years.
If measures are not taken to facilitate rural mail box delivery, it can be expected that employees will continue to raise concerns about strains and related injuries. Canada Post has both a moral and a legal obligation to ensure the health and safety of its employees. These injuries not only have a human toll but are also creating additional expense for the Corporation for the costs associated with injury on duty, replacement workers, or the addition of a second person in the delivery vehicle to assist the delivery agent. It is expected that the adoption of the proposed changes would enable Canada Post to save in the range of $10 million to $15 million annually.
The changes to the dimensional specifications for mail box assemblies would provide building owners with greater choice and flexibility when purchasing and installing mail box assembly units. The installation of secure parcel units, either outside or inside apartment buildings or office complexes, would benefit consumers and businesses by providing them with more convenient access to their parcels and reducing the risk of theft. Centralized delivery would also enable delivery agents to deliver parcels in a more cost-effective and secure manner.
The amendments would not require building owners to incur any additional costs. The installation of parcel-only compartments would remain non-mandatory, and the units could be installed at the option of either the property owner or Canada Post. It is anticipated that most parcel units would be installed by Canada Post at its own expense. Permitting the installation of boxes of a different configuration than is allowed at present would enable building owners or Canada Post to take advantage of the other sizes available in the marketplace at competitive prices. Such units would need to meet rigorous security standards. Canada Post would continue to provide the required locks and keys.
The “One-for-One” Rule does not apply to these proposals, as there is no change in administrative costs to business.
Small business lens
The small business lens does not apply to these proposals, as there are no costs to small business.
Research and experience have shown that the height of a mail box plays an important role in the safe and efficient delivery of mail. During the development and testing of the reaching device, independent ergonomic specialists were consulted. Canada Post has also entered into extensive consultations with the Canadian Union of Postal Workers, the bargaining agent representing employees who deliver and pick up mail from rural mail boxes.
No specific consultations have taken place on the amended specifications for mail box assemblies or the addition of the specifications for parcel unit assemblies, given that most new parcel units would be installed by Canada Post at the company’s expense and the amendments would not require building owners to replace existing mail box or parcel units.
The Canada Post Corporation Act requires a consultation period through publication of each regulatory proposal in the Canada Gazette. All representations must be sent to the Minister of Transport. The representations are taken into consideration in the preparation of the final regulatory proposal.
The height of the vehicles used in the delivery of mail in rural Canada varies greatly. Testing has shown that adoption of the proposed changes to rural mail box specifications would compensate for the differences in the window height of the various vehicles that are being used for delivery and allow for the safe delivery of mail to rural customers. Adoption of the proposed amendments would also lessen the risk of personal injury due to over-stretching or repetitive, awkward positioning by facilitating the use of the reaching device.
Currently, not all mail box assemblies in apartment buildings or office complexes have secure parcel compartment units. There is a growing need for such units, given the increasing popularity of e-commerce. The amendments would allow parcel compartment units to be installed either inside or outside the building, which would give residents and businesses secure and convenient access to their parcels and make delivery more cost-effective.
Implementation, enforcement and service standards
Canada Post has a long and proud history of serving rural Canada. These proposed changes will help facilitate the delivery of mail in an efficient manner while ensuring the health and safety of delivery employees.
The amendments pertaining to rural mail boxes, if approved, would apply to all existing and future customers who receive mail delivery via a rural mail box. Canada Post would notify those customers whose rural mail boxes are non-compliant and provide them with a list of required modifications. When doing so, Canada Post would inform the customers of a contact person from whom they could obtain additional information. Existing customers would be notified within 12 months following adoption of the amendments, and would have 30 days to make the required modifications. No notifications would be provided during winter months.
The amendments pertaining to both rural mail boxes and parcel boxes would come into force on registration by the Clerk of the Privy Council.
The Regulations are enforced by Canada Post under the Canada Post Corporation Act. No increase in the cost of enforcement is expected as a result of the proposed changes.
Canada Post Corporation
2701 Riverside Drive, Suite N0980C
PROPOSED REGULATORY TEXT
Notice is given, pursuant to subsection 20(1) of the Canada Post Corporation Act (see footnote a), that the Canada Post Corporation, pursuant to subsection 19(1) (see footnote b) of that Act, proposes to make the annexed Regulations Amending the Mail Receptacles Regulations.
Interested persons may make representations concerning the proposed Regulations within 30 days after the date of publication of this notice. All such representations must cite the Canada Gazette, Part Ⅰ, and the date of publication of this notice, and be addressed to the Minister of Transport, House of Commons, Ottawa, Ontario K1A 0A6.
CANADA POST CORPORATION
REGULATIONS AMENDING THE MAIL RECEPTACLES REGULATIONS
1. The definition “parcel compartment assembly” in section 2 of the Mail Receptacles Regulations (see footnote 1) is replaced by the following:
“parcel compartment assembly” means all parcel compartment units installed inside or outside an apartment building or office complex; (batterie de casiers à colis)
2. Subparagraphs 16(b)(i) and (ii) of the Regulations are replaced by the following:
- (i) the box is securely attached to a fixed post,
- (ii) the bottom of the box is not less than 105 cm and not more than 115 cm from the ground immediately below,
3. Section 3 of Schedule III to the Regulations is replaced by the following:
3. The interior of each mail box in a mail box assembly shall measure
- (a) at least 35 cm in length; and
- (b) at least 7.5 cm each in height and width and
- (i) in the case where one of those dimensions measures less than 12.5 cm, the other dimension shall measure at least 25 cm, and
- (ii) in the case where one of those dimensions measures 12.5 cm or more, the other dimension shall measure at least 13.5 cm.
4. Subsection 8(2) of Schedule III to the Regulations is replaced by the following:
(2) The lock shall be fitted so that, when it is locked, the bolt is engaged in metal to a depth of at least 6 mm.
5. The heading of Schedule IV to the Regulations is replaced by the following:
CONDITIONS AND SPECIFICATIONS FOR PARCEL COMPARTMENT ASSEMBLIES
6. (1) The portion of section 1 of Schedule IV to the Regulations before paragraph (a) is replaced by the following:
1. Mail shall be delivered to a parcel compartment assembly if
(2) Paragraphs 1(b) and (c) of Schedule IV to the Regulations are replaced by the following:
- (b) the local postmaster has approved the delivery of mail to the assembly;
- (c) the assembly is readily accessible to the occupants of the building and to post office representatives;
(3) Paragraph 1(f) of Schedule IV to the Regulations is replaced by the following:
- (f) the interior dimensions of each individual storage compartment are not less than 7.5 cm by 25 cm by 35 cm;
(4) Section 1 of Schedule IV to the Regulations is amended by adding the following after paragraph (g):
- (h) the bottom row of individual storage compartments is not less than 38 cm from the finished floor level; and
- (i) the assembly has a return slot that permits keys to be deposited securely after a parcel has been retrieved from an individual storage compartment.
7. Subsection 3(1) of Schedule IV to the Regulations is replaced by the following:
3. (1) The Corporation shall provide a lock mechanism and a key for each individual storage compartment.
COMING INTO FORCE
8. These Regulations come into force on the day on which they are registered.