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College and University Mail Center Security
Opryland Hotel
Nashville TN
College & University Track
Session 14
10:30 – 11:45 AM
March 23, 2005
Your Presenter
John P. Golding
SuperintendentPostal & Distribution Services
Northern Virginia Community College
Annandale VA
Over 45 years experience in the Postal, Distribution & Safety
Fields.
MEMBER OF:
USPIS-BMITF
ARMCUMS - UMMA
National Safety Council
CSHEMA Div of NSC
Chesapeake Region (NSC)
EXECUTIVE BOARD MEMBER:
NACUMS
CUMSA - MARCUMS
Virginia Community College Association
ACKNOWLEDGEMENTS
Taylor Golding – Granddaughter – 8th Grade – DMMS – Winchester VA
Alison W. Baker JD – VP F&AS – NVCC – Annandale VADon D. Delmanzo – Dir. Fac. Mgt. – NVCC – Annandale VA
Roger Tancreti – Asst. Director S&SS – NVCC – Annandale VABarbara Shufflebarger – DHRM – NVCC – Annandale VA
F Kristin McClaren – VA-DHRM/WC – Richmond VA
Cheryl George – Lebanon Valley College – Annville PA
Anthony Prisco – USPS – BSN – No. VA Dist. – Merrifield VAUnited States Postal Inspection Service – Dulles VA
Fairfax County (VA) Department of Fire & EMS Services
NVCC – Postal & Distribution Services Team
College and University Mail Center Security
This session will cover a broad overview of security concerns and issues
Postal Operations in the C & U Setting shows that we are a diverse & unique industry.
The Big Box Store principal does not apply.
Each C&U Mail Center reflects the character and style of the individual Institution.
Mail Bombs, Anthrax & Ricin
Today we are not going to go down this road, they were covered in
several other sessions here @ the NPF
Need information on these subjects contact
the US Postal Inspection Service and
request their Law Enforcement Packet
Today we are going to touch on:
Security issues:
Operational Authority
Disaster Plan
Physical Locations
Employees
Training & Marketing
Liabilities
Type of Mail:
Official Business
Generic Addressed
Student
Bulk / Unsolicited
& finish with
Food for Thought
Operational Authority
REFERENCE:
USPS - Domestic Mail Manual
Article: DO422.3.0Conditions of Delivery
Section: 4.0 Delivery to Individual at
Organization
Sub:4.1To Address:
All mail addressed to a governmental or nongovernmental organization or to an individual by name or title at the address of the organization is delivered to the organization, as is similarly addressed mail for former officials, employees, contractors, agents, ect.
If disagreements arises where any such mail should be delivered, it must be delivered under the order of the ORGANIZATION'S PRESIDENT or equivalent official.
Operational Authority
NORTHERN VIRGINIA COMMUNITY COLLEGE
ADMINISTRATIVE SERVICES PROCEDURES MANUAL Section 27 POSTAL & DISTRIBUTION SERVICE CENTER Revised September 2002
As the Agent for Commonwealth of Virginia and Northern Virginia Community College;
The Superintendent of NVCC Postal & Distribution Services;
Is designated to have the right to open, inspect, reject, and determine disposition of any and all items presented for receiving, shipment, processing or distribution thru the NVCC Postal & Distribution Services Operation.
Disaster Plan
Do you have a written disaster plan?
Is it review & updated?
Whom is it shared with?
Pre-Emergency Planning
SIMPLE EMERGENCY
MAJOR EMERGENCY:
DISASTER: Keep planning simple.
Contents of planning must be exercised.
PHASED PLANNING (conducted in three increments).
Before something happens: Plan development unique to Your Operation on Campus
When it happens / while it is happening:
Emergency Response.
After it happens: Recovery and Continuity
of Operations.
Establish Working Relationships
Emergency Services Side:
Campus Police / Security
Local & State Law Enforcement
Local Fire & EMS
Local Post Office, USPS-BSN & USPIS
Local Industrial Safety & Security Departments
On your campus:
Facilities Management Department
Human Resources
Workers Compensation
College Marketing & Public Affairs
Administrative Groups
Physical Locations
PUBLIC AREAS
Your Lobby, Boxes, & Counter Area
ARE THEY SECURE
WELL LIGHTED
VIEWABLE
Are You Asking for Trouble?
Does your area invite loitering, trash & ect.? Do your boxes accommodate the customer? These are security & safety concerns
Work & Processing Areas
MAIL PROCESSING AREAS ARE THEY:
SECURE & RESTRICTED
WELL LIGHTED & VIEWABLE
THE SAME FOR YOUR DOCK AREAS
Physical Security
Have security guards greet all visitors and examine personal belongings being brought into the building or office area
Restrict access to the facility or office through locked or guarded entryways.
Keep storage rooms, boiler rooms, telephone closets, and similar hiding places locked or “off-limits” to visitors.
Use easily distinguishable identification badges for staff personnel and for visitors.
Require visitors to be accompanied by staff employees to and from the office or facility entrance.
Physical Security
Request visitors to display identification to security personnel when they sign in (keep detailed logs on all visitors’ times of
arrival and departure).
Require that all non-postal courier deliveries exceeding 1 pound
be made through mail center screening personnel.
Obviously, commercial bulk deliveries would be excluded.
It is recommend that you consider using the services of a Certified Protection Professional to evaluate your personnel and physical security safeguards in detail.
Full & Part Time Employees
Subject to Pre-Employment Screening to include Drug Testing & Driver License Review
Follow-up testing and reviews as required
Do you furnish continual Professional Development Training
To include Customer Service, Security & Safety Programs
Student Employees
Do you require
the same
pre-employment and annual reviews from
your student employees as you do for your full or
part time employees?
WHY NOT?
Who do you train?
ALL EMPLOYEESFULL, PART TIME & STUDENTS
Emergency Response Plan (ERP):
Plan, Train, Revise...
We will respond the way "we" trained...
Ensure Security & Safety...
Training & Marketing
Do you have an established training program?
How in depth is it?
Do you update it?
Is it training or Lip Service?
Or do you just react when something happens.
Do you offer your training courses to:
Invite representatives of campus groups to attend
your training sessions
Campus &/or College Working Groups
Example would be to sponsor & provide outside experts to
talk to your college secretarial & administrative
groups
TRAINING It’s cost efficient - Most of it is FREE
Sources:
US POSTAL INSPECTION SERVICE
USPS – BUSINESS SERVICE NETWORK
STATE / LOCAL LAW ENFORCEMENT
FIRE DEPARTMENT, EMS & HAZ-MAT TEAMS
INDUSTRY SECURITY & SAFETY TEAMS
YOUR INSURANCE CARRIER
Free TrainingAvailable from the USPS website
The USPS & USPIS offer for FREE the following DVD’s
Identity Crisis."Dialing for Dollars"
Work at Home Scam
Show them to your employees & offer them to your
College Professional Development Team to show college-wide
"Bomb Threat Response:”
New Training Program to Help Schools Deal with Bomb Threats
The Bomb Threat CD-ROM was developed by the U.S. Department of Justice's Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
and the U.S. Department of Education's (DOE) Office of Safe and Drug Free Schools.
The Bomb Threat CD-ROM is a FREE interactive planning tool for schools that included staff training presentation and implementation
resources.
ATF distributed the CD-ROM to State and local law enforcement and public safety agencies.
DOE Office of Safe and Drug Free Schools handled distribution to the country's public and private school systems.
Order one for your operation: http://www.threatplan.org/
Hazardous Materials
If your involved with it, do you have a written policy for handling & processing
it thru your operation?
Are you in compliance with the rules & regulations of USPS, DOT & OSHA?
Have you trained your employees?
Suggest you do it, an incident can have dramatic & costly results.
Hazardous Materials
If you deal with Common Carriers.
The U.S. Department of Transportation (DOT) is the federal agency responsible for regulating the carriage of hazardous materials within the United States via any mode of transportation (i.e., highway, rail, air, water).
The federal regulations of DOT are codified in Title 49 Code of Federal Regulations (49 CFR). 49 CFR contains DOT's detailed specifications for packaging, marking, and labeling hazardous materials.
Title 49 also exempts or establishes other requirements for limited quantities and small quantities of hazardous materials.
Many times different quantities of the same product may or may not be regulated for shipment. A quart may not be regulated, but a gallon container might be.
Hazardous Materials & the U S Postal Service
The carriage of U.S. Mail by the Postal Service is regulated by Title 39 Code of Federal Regulations
(39 CFR) and is not subject to the federal regulations
In 49 CFR as commercial carriers are.
Unlike the commercial carriers, the Postal Service is, however, subject to the restrictions in
Title 18 United States Code 1716 (18 U.S.C. 1716), which prohibits from mailing all matter that is outwardly or
of its own force dangerous to life, health, or property
Domestic Mail Manual C020–C024
Publication 52, Hazardous, Restricted and Perishable Mail
Accordingly, for legal and safety reasons, the postal mailing standards for hazardous materials in DMM C023 and Publication 52 not only closely adhere to 49 CFR, but also include many additional limitations and prohibitions.
In many instances, the postal standards are more restrictive than the requirements of other commercial carriers.
For example, 49 CFR allows commercial shippers to send flammable materials by air, but the Postal Service prohibits the mailing of all flammable materials via air transportation.
As a result, most hazardous materials are nonmailable.
HAZ-MAT TRAINING
One of the primary goals of training is the
Identification of Hazardous Materials Most errors occur, because an employee did not know it was
hazardous to begin with
Creating an awareness of HAZ-MAT issues and the need to do it right the first time.
Many times different quantities of the same product may or may not be regulated for shipment.
A quart may not be regulated, but a gallon container might be
Try to cover all of the possible scenarios and reinforce that it’s okay—even a job requirement—to ask questions
if they do not fully understand how a item is to be Safely & Securely handled
HAZ-MAT / MSDS
We have found that the best way to reduce possible exposure is to have your purchasing staff made aware
of the need to identify hazardous materials.
Then insure the proper Material Safety Data Sheets (MSDS) are in the hands of your
hazardous materials receiving person prior to the product arriving at your dock.
This requires your purchasing staff to ask about an MSDS for any new products being ordered
and the necessity for your vendor to get them to your operation in a timely manner.
DON’T RE-INVENT THE WHEEL!
HELP IS A CLICK AWAY
VISIT THIS OSHA SITE
http://www.osha.gov/SLTC/hazardcommunications/index.html
U.S. Department of LaborOccupational Safety and Health Administration
DRAFT MODEL TRAINING PROGRAM FORHAZARD COMMUNICATION
Workers Compensation Carrier State & Local Governmental Agencies
Public College or University contact your State Department of Workers Compensation or your
State Department of Labor & Industry
Private Institution contact your Workers Compensation Insurance Carrier
Or agencies of your State or Local Government
The following two slides are an example of the type of training available.
Workplace Violence:General Awareness Training
Jan Thomas, PhD, CSP
Circle Safety & Health Consultants Richmond, VA
“Fire Safety Awareness”and Fire Extinguisher Training
for Fairfax County DPWES Employees
This training module was developed in cooperation with the National Fire Protection Association and the Public Information and Life Safety Education Section of the
Fairfax County Fire & Rescue Department 4100 Chain Bridge Road, Fairfax, VA 22020www.co.fairfax.va.us/ps/fr/general/Piolse.htm(703) 246-3801 or (703-385-4419 TTY
Portions Copyright 1995-2000 by Dr. Robert Toreki, used by permissionhttp://www.ilpi.com/safety/extinguishers.html
Liabilities
Do Not Assume Anything - Be Pro-Active
You can not prevent every incident, BUT… You can limit the Liabilities…
Personal Injuries & lives, Property Damage,Destruction, Theft, & the list goes on & on….
Think about the Dollars & or Bad Publicity it could cost your
College or University & possibly yourself.
OFFICIAL BUSINESS MAIL
We handle & process it both Inbound & Outbound.
In addition to the USPS & College/University Rules & Regulations we operate under.
There is a Federal Law that mandates Security
It is the
The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99)
The Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99)
FERPAis a Federal law that protects the privacy
of student education records.
The law applies to all schools that receive funds under an applicable program of the
U.S. Department of Education.
FERPAWhat does it cover?
Just about anything that pertains
to the student
Financial Aid Info
Grades
Personal Information
Transcripts
Other types of Official Business
To name a few:
Administrative Correspondence
Fiscal Items & Checks
Human Resource Correspondence
Procurement Contracts
Purchase Orders
General Business Mail
Generic Addressed MailInbound – First Class or EMS
Do You have a written Policy & Procedure for handling & processing these items?
Who has the authority to open & process this type of Mail?
If you process it in your operation do you have a ID stamp to show who processed it.
UAA MAIL
Undeliverable As Addressed MailDo you have a written policy?
1st Class – Former Faculty or StaffForward to the division office or Return to Sender
Bulk Mail – Recycle Or consider joining a group such as
Ecological Mail Coalition - http://www.ecologicalmail.org/Intra-Mail Network, Inc. – http://www.intra-mail.com
STUDENT MAIL
If your operation is responsible
Treat it the same as Official Business Mail
Your not responsible for Student Mail?
That’s the responsibility of:
Residential or Housing Department.
Think Again!
If there is a problem WHO will get the phone call?
The Irate Parent will call and ask for the Campus Post Office or Mail Service now the ball is in your court.
STUDENT MAIL
If Student Mail is not your responsibility consider offering or obtaining training for those that
handle it
Outsiders do not know your internal operations, mail service is mail service to them
Any problem with any mail delivery reflects on the C&U as a whole and indirectly on
your Mail Operation
US POSTAL INSPECTION SERVICE
Inspectors in the News 1/7/2004
Former U of XX student charged with stealing 700 classmates' credit
(AP) -- A former University of XX criminal justice major is going to federal prison for more than three years for stealing credit and mail from more than 700 classmates.
Court records show the thefts started in 1999 when (The Person),
who is now 23, took a job as a mailroom clerk at an off-campus dorm The thefts lasted until August 2002.
Postal inspectors say (The Person) routinely stole student mail containing new credit cards.
Then waited ten to 12 days to steal follow-up letters containing the activation codes.
Bulk & Unsolicited Mail
Do you have a written policy?
Properly address Mail is processed
Improper addressed 1st Class is Returned
Improper Addressed Bulk Mail is recycled
Are you recycling properly?
Security & Incident Scene Photography
In addition to closed circuit TV or video monitoring
Consider a digital camera as a necessary tool
To assist in criminal & injury claims cases
To help protect your institution and yourself against
False claims, potential fraud and to limit your liability,
A picture is worth a 1000 words!(BUT…Make sure the correct date is set on it prior to snapping the picture)
Food For Thought
Think of Cell Phones as a security issue.
They can be turned on during a meeting and transmit Verbal Information or
Your Comments to a remote location.
Also a Photo Phone can transmit photos of Attendees, Presentations & Items of a
Confidential nature to a remote location.
Food For Thought
Remember When dealing with people
Any incident or issue be it large or small can become a
SECURITY or SAFETY CONCERNThink of:
PERSONAL ATTITUDEHORSE PLAY ROAD RAGE
And so on & so forth….If it impacts your operation, it’s a concern
College &University Mail Services are UNIQUE
What works for me might not work for you.
The same holds true in reverse.
But we have several things on our side that most other mailing industries do not have.
NACUMS
Our Seven (7) Regional Associations
& last but not least - CUNI-MAILWhen it comes to Security, Safety & other issues; the
only foolish question is the one that is not asked.