ASM Revision: Participation in Community Service Activities

Effective January 19, 2017, the Postal Service^™ is revising the Administrative Support Manual (ASM), section 333.7, Participation in Community Service Activities (CSAP). This is the first update of the CSAP since it was implemented in 1999. The revised policy addresses new issues that have arisen in recent years regarding employee involvement in community activities, deletes obsolete provisions, clarifies covered activities, provides relevant examples, includes a revised request form, and outlines the specific processes that field and headquarters employees must follow when seeking official approval of covered activities.

Administrative Support Manual (ASM)

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3 Communications

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33 Communications With the Public

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333 Community Relations

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333.7 Participation in Community Service Activities

333.71 General

333.711 Purpose

[Revise 333.711 to read as follows:]

The community service activities policy (CSAP) is designed to assist the Postal Service and its employees in contributing to the health and well-being of the communities it serves, and to maintain and enhance its connection with the community while fulfilling its mission of accepting, processing, and delivering the mail reliably and efficiently.

333.712 Definitions

[Revise item b. to read as follows:]

b. Charitable sponsorship means paying all or part of the entrance fee for an event on behalf of one or more Postal Service employees when such fee exceeds the actual cost of participation and when this excess amount is, in effect, a donation to a non-profit organization.

333.713 Scope

[Revise items b(2), b(4), and b(6) to read as follows:]

b. Activities Not Covered. The following community service activities are governed by the cited statutes and regulations, or other postal policies, and are therefore not covered by this policy:

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(2) The Postal Employees’ Relief Fund (charitable organization; www.postalrelief.com).

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(4) Blood drives and marrow, stem cell, platelet and organ donation (ELM 519.51 and 519.52).

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(6) Disposal of undeliverable mail (Postal Operations Manual (POM) 691.5).

[Add new items b(8) through b(12) and renumber current item b(8) as new item b(13); revise the Note to read as follows:]

(8) The National Association of Letter Carriers (NALC) Food Drive.

(9) Wearing a postal uniform for a non-operations purpose or in connection with an unofficial event (ELM 931.263 and 934.6).

(10) Use of an official Postal Service vehicle for non-operations purposes, i.e., parades, funerals, community displays, etc., that do not fall within the CSAP (such use requires approval by the vice president, Delivery Operations, and appropriate Area vice president).

(11) Use of postal funds and/or postal time for purposes that do not fall within the CSAP.

(12) Operation Santa programs (Corporate Communications).

(13) Other programs established by Postal Service regulations or approved by the Postmaster General.

Note: Postal Customer Council (PCC) postal and industry members interested in PCC participation in charitable and/or community service activities should check Publication 286, Postal Customer Council Program Policies & Rules (March 2007 or updated version, if any), and contact the Ethics Office for guidance.

[Revise the title and text of 333.714 to read as follows:]

333.714 Approval Process and Responsibility

Employees should seek approval only for activities that appear to comply with this policy and that they are willing to sponsor. District managers may reject proposed activities without seeking higher-level approval for requests.

a. Field personnel must follow these steps:

1. Submit a PS Form 3337-A requesting preliminary approval for the activity to the district manager.

2. If the district manager denies the request, the activity is not eligible for approval by the Area vice president.

3. If the district manager approves the request, he/she forwards it to both the Area vice president and the managing counsel of the appropriate Field Law Office.

4. Participation in the activity is permitted only if the Area vice president provides final written approval.

b. Headquarters personnel must follow these steps:

1. Submit a PS Form 3337-A requesting approval for the activity to the appropriate headquarters officer, and a copy of the request to the Ethics Office.

2. Participation in the activity is permitted only after the headquarters officer provides final written approval.

[Add new 333.715 to read as follows:]

333.715 Questions and Guidance

Questions and requests for guidance on this policy should be directed to the Ethics Office at 202-268-6346 or ethics.help@usps.gov, or to the appropriate Field Law Office.

333.72 Criteria

333.721 Mandatory Criteria

To be approved, a community service activity must meet the following mandatory criteria:

[Revise item a(5) to read as follows:]

a. Subject Matter. A community service project, event, or cause must fit within at least one of the following categories:

* * * * *

(5) Promoting wellness (including, but not limited to, activities related to medical research, physical fitness, mental health).

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[Add new item b. and renumber current items b. and c. as new items c. and d. with text revisions to read as follows:]

b. Existing activity. An eligible community service project, event, or cause is one that existed prior to any postal involvement. It must not have been created wholly by the postal employees who seek approval to participate in it. For example, employees may seek approval to participate in a clothing drive sponsored by a community homeless shelter, but not to create their own “freestanding” clothing drive unrelated to an existing community drive.

c. Avoid Controversy. A supported project, event, or cause must not be political or religious, or likely to involve the Postal Service in controversy. Supported activities should not be sponsored by a political or religious organization.

d. Increase Brand Value. Support of a project, event, or cause must reflect favorably on the Postal Service and enhance the value of its brand.

333.722 Suggested Criteria

[Revise 333.722 to read as follows:]

In determining whether to support a particular charitable project, event, or cause, it is appropriate to consider whether this support is likely to benefit the Postal Service in some additional manner, such as by enhancing labor-management relations, employee engagement, and employee development (e.g., managerial, technical, or interpersonal skills), or promoting Postal Service products and services.

333.73 Employee Activity

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333.732 Off-the-Clock

[Revise 333.732 to read as follows:]

The Postal Service encourages its employees to volunteer on their own time and in their personal capacities for the charities and causes of their choice, and to voluntarily contribute to the charities of their choice on their own or through the annual Combined Federal Campaign.

Any employee who wishes to serve a charitable organization as one of its executives or board members should seek advice from the Ethics Office before doing so.

The wearing of Postal Service uniforms while off-the-clock is governed by section 934.6 of the Employee and Labor Relations Manual (ELM).

333.74 Postal Service Property and Postal Service Funds

333.741 Postal Service Property

[Revise items a. and b(3) and add new item b(4) to read as follows:]

a. Communications Equipment. An accountable manager may approve incidental use of Postal Service communications equipment (computers, phones, iPads, fax machines, photocopiers, etc.) and resources (email, wireless, etc.) to disseminate information about a community service event or project for which employee work hours have been authorized under 333.731.

b. Vehicles or Facilities.

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(3) Postal Service regulations regarding Conduct on Postal Service Property (39 C.F.R. Part 232.1). [Note: COPP prohibits the solicitation/collection of charitable donations anywhere on postal property (except as authorized by the Combined Federal Campaign). However, in non-public (generally, employee-only) areas of postal facilities, employees may solicit for and collect nonmonetary donations from employees for activities that have been specifically approved under the CSAP.]

(4) Management Instruction FM 530-2013-5, General Policy Regarding the Use of Government or Postal Owned or Leased Vehicles, states the following:

n Only an appropriately-rated Postal Service employee may operate a Postal Service vehicle.

n The Postal Service does not loan its vehicles to other organizations.

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333.742 Postal Service Funds

[Revise item b. and add new item c. to read as follows:]

b Charitable Sponsorships [see definition at 333.712(b)]. An accountable manager may sponsor the participation of one or more employees in a community service event requiring a participation fee if all of the criteria in 333.721 are met, and if there is adequate funding in an existing budget to pay for the sponsorship. Accountable managers should consult with Finance before approving, under this policy, the use of postal funds related to a community service activity.

c. Any other use of Postal Service funds to support community service activities will not be approved.

333.75 Questions and Answers About the Postal Service’s Community Service Policy

333.751 General

[Revise 333.751 to read as follows:]

Q1 The Postal Service serves communities all over the country by delivering mail. Why should it do anything else?

A1 Community service not only helps others, it also helps boost employee morale and enhance the Postal Service’s public image. The better our employees feel about the organization, the more engaged and motivated they will be to make it succeed. Further, our business and reputation benefit when customers view the Postal Service as a positive force in their community.

Q2 How should we publicize our successful community service projects?

A2 Contact communications specialists to assist with efforts to place information about approved community service projects in internal and/or external publications and venues, consistent with the Postal Service’s corporate communications policies.

333.752 Causes That May Be Supported

[Revise 333.752 to read as follows:]

Q3 Does the Postal Service focus on certain causes?

A3 The policy lists six approved causes:

1. Assisting disaster victims.

2. Relieving hunger.

3. Promoting education/literacy.

4. Enhancing the environment.

5. Promoting wellness.

6. Promoting child safety and well-being.

Q4 The (fictitious) “Community Closet” organization is sponsoring a toys and coats drive for children. A postal employee requests approval to set up a collection bin in the employee break room so employees can participate in the drive. May this request be approved?

A4 Yes. If the employee’s district manager concurs with the request, the Area vice president (AVP) may approve it. The coats and toys drive is an existing and approved cause (“Promoting child safety and well-being”), is being conducted in an employee-only area of the office, and involves soliciting/collecting only from employees. If a headquarters employee had made this request, the headquarters officer could approve setting up a collection bin for employee donations in a nonpublic headquarters location (i.e., an area accessible only after passing through security, not including the onsite coffee shop or the snack bar).

Q5 Suppose the (fictitious) civic association named “Keep Downtown Beautiful” organizes an effort to restore Ye Olde Inn, a local landmark in Centertown. May postal employees be authorized under CSAP to assist with restoration efforts?

A5 No, because “preserving history” is not a CSAP-approved cause. The Postal Service can best leverage its limited resources by focusing on just a few worthwhile causes. Postal Service employees may participate in such activities in their personal capacities, on their own time.

333.753 Acceptable Actions by the Postal Service and Employees

[Revise 333.753 to read as follows:]

The following questions and answers concern acceptable actions by the Postal Service and its employees regarding sponsoring employees, donating work hours, and publicizing events.

Q6 Employees at the Pleasantville Post Office want to take part in a back-to-school collection sponsored by a local television station. The activity will involve collecting backpacks and school supplies from employees, and then delivering the items to the television station while on the clock and using a postal vehicle. May the AVP approve the activity?

A6 Yes. This is an appropriate cause (“Promoting child safety and well-being”), and the AVP may approve not only the collection of these items from employees, but also the on-the-clock use of a postal vehicle to deliver them (with an authorized postal driver).

Q7 Suppose a (fictitious) organization called “Crisis Care” organizes a 5-mile walk for cancer survivors and their families, and three postal employees want to participate. The registration fee is $500 per person. May the AVP or headquarters (HQ) officer approve Postal Service sponsorship these employees?

A7 It depends. The amount of the registration fee, $500, indicates that the fee is largely a straight charitable donation (i.e., beyond the amount necessary to cover the cost of participating in a 5-mile walk). Although “promoting wellness” is an approved cause, consider whether using $1,500 in postal funds to sponsor three employees’ participation in this event is likely to raise appearance and “special treatment” concerns. A lower registration fee, for example an amount under $50, would be less likely to raise these concerns. No official below the vice president/officer level may approve a charitable sponsorship, or any other community service activity.

Q8 Centertown’s “Keep Downtown Beautiful” organization schedules a clean-up day in the spring, and asks all local businesses to help pick up trash, plant flowers, and paint over graffiti. Employees at the Centertown Post Office want to help out. Is this an eligible activity under the policy?

A8 Yes. Enhancing the environment is an approved cause, so the employees may voluntarily participate if approval is obtained from their AVP (employees must never be directed or pressured to participate in a community service event). And, of course, the Postmaster must put the needs of the Postal Service first — employee participation in the clean-up cannot interfere with, or detract from, the successful completion of Postal Service business.

Q9 Suppose “Keep Downtown Beautiful” asks the Postal Service’s participants to make copies of a flyer to publicize the clean-up day. May the AVP approve this request?

A9 Yes, if the AVP approves employee participation in the clean-up day under the CSAP, he or she may also allow employees’ incidental use of Postal Service resources (for example: paper, copier, computer) to create and/or make copies of a flyer.

333.754 Unacceptable Actions by the Postal Service and Employees

[Revise 333.754 to read as follows:]

The following questions and answers concern unacceptable actions by the Postal Service and its employees regarding collections of non-monetary items, loaning vehicles, waiving postage costs, donating money, raising funds from employees and customers, and sponsoring events.

Q10 The Nicetown Chamber of Commerce is sponsoring a toiletries drive to benefit local shelters. A group of Nicetown Post Office employees have asked if they may participate in the drive by encouraging community members and employees to leave donations of shampoo, toothpaste, combs, and other items in collection bins set up in the Post Office lobby. May the AVP approve this request?

A10 No, not if the employees intend to solicit donations from the public and place collection bins in the lobby. Employees may not solicit donations — monetary or non-monetary — from customers and members of the public. In addition, collection boxes for charitable donations may not be set up by anyone in any area open to the public at any postal location. However, the Nicetown employees may participate in the toiletries drive if they solicit donations only from postal employees, and collect the employee donations in an employee-only area of their facility.

Q11 Carriers at the Pleasantville Post Office want to participate in a back-to-school drive to collect school supplies. The drive is organized by a local postal union and television station in Pleasantville, and will solicit donations from the public. The carriers would like to park their postal vehicles during their lunch breaks at various drop-off points throughout the city so members of the public can come by with donations. May the AVP approve this?

A11 Only if the carriers are not involved in soliciting the public for donations. If the solicitation for donations is conducted by the union and/or television station, and the carriers’ only involvement will be to collect the donations at drop-off points, the AVP may approve the activity.

Q12 Suppose the Centertown Postmaster seeks approval under this policy to allow Centertown Post Office employees to participate in a “Keep Downtown Beautiful” event. The Postmaster plans to assign employees to participate with specific tasks, such as picking up trash, planting flowers, painting over graffiti, etc. May the Postmaster assign employees to help out?

A12 No. The Postmaster may not direct, order, or pressure employees to participate in a community service event, even if it has been approved by the AVP. Employee participation in CSAP activities must be voluntary. Unless there is employee interest in voluntarily participating in this activity, the Postmaster should not seek approval for it under the CSAP.

Q13 If the “Keep Downtown Beautiful” organization needs a vehicle to haul painting and gardening equipment for Spring Clean Up Day (see Q8), may the Postmaster loan one out to the organization for a day?

A13 No. The Postal Service does not loan its vehicles to other organizations. However, the AVP may authorize an appropriately-rated employee to operate a vehicle in connection with an approved community service activity. In deciding whether to authorize use of a Postal Service vehicle, the AVP must weigh the risk of an accident or injury resulting from the proposed use and the possible costs to the Postal Service of an accident or injury.

Q14 Suppose “Keep Downtown Beautiful” wants to mail out flyers about Spring Clean Up Day. May the Postal Service waive the cost of postage?

A14 No. The Postal Service may send out a mailing about an approved community service event only if the mailing is done under the Postal Service’s own name and using its own mailing permit. The Postal Service will not waive or reduce the cost of postage for any customer.

Q15 Suppose “Crisis Care” asks the Postmaster for a $100 donation, and the Postmaster requests approval for the donation through the CSAP. May the AVP approve the request?

A15 No. The AVP must deny the request because the policy does not authorize the outright donation of Postal Service funds, even for an approved cause. Requests under the CSAP must be made by a postal employee or employees, and involve some level of employee participation.

Q16 Suppose “Crisis Care” asks the Postmaster to encourage employee contributions to its annual fundraising campaign, or to allow someone from “Crisis Care” to attend a stand-up talk and seek donations. May this request be approved?

A16 No. Federal and postal regulations prohibit the solicitation of charitable donations in the workplace and on postal owned or controlled property. Postal employees may only be solicited for charitable donations in the workplace through the Combined Federal Campaign (CFC). This request should not be submitted through the CSAP process. Instead, the Postmaster must deny Crisis Care’s request, but may suggest that the organization contact the local CFC agency to find out how to apply to become an approved CFC charity.

Q17 Suppose “Crisis Care” asks the Postmaster for permission to set up a table in the Post Office lobby so that it can solicit donations from Postal Service customers. May this request be approved?

A17 No, the Postmaster must also decline this request. Although the CSAP permits the incidental use of Postal Service facilities in conjunction with an approved project or event, the use must comply with the Conduct on Postal Property regulations (COPP). The COPP regulations prohibit the solicitation and/or collection of monetary donations on property owned or leased by the Postal Service, other than through the CFC. Non-monetary items may be solicited for and collected from postal employees when authorized under this policy, but only in employee-only areas of a facility.

Q18 Suppose “Crisis Care” is bringing a popular entertainment group to the local civic center for its biggest fundraiser of the year, and it offers the Postal Service the opportunity to be an official sponsor. For $20,000, the Postal Service could have its name and logo on all promotional materials, souvenirs, banners, etc., to promote its products and services at the event. May this request be approved?

A18 No. This request may not be considered under the CSAP because it is a sponsorship request from an outside organization, not an employee request for approval of employee participation in a community service activity. Refer Crisis Care’s sponsorship request to the director, Brand Marketing (Marketing); manager, Brand and Policy (Corporate Communications), and chief counsel, Procurement/Intellectual Property Law (Legal).

333.755 Organizations the Postal Service May or May Not Work With on Community Service Activities

[Revise 333.755 to read as follows:]

The following questions and answers concern the acceptability or unacceptability of the Postal Service and its employees working on community service activities with unions and management associations, religious organizations, political groups, and controversial groups.

Q19 How does this policy affect the annual food drive sponsored by the National Association of Letter Carriers (NALC)?

A19 The policy does not cover or affect the annual NALC food drive, which is governed by a longstanding agreement between the NALC and the Postal Service. The food drive is a postal-approved activity managed separately from the CSAP.

Q20 Suppose the (fictitious) “First Baptist Church” organizes a campaign to provide clothing to people whose homes were destroyed by a hurricane. Its minister asks the Postmaster whether letter carriers could pick up donations from people’s homes and bring them to a collection center. Can this request be approved?

A20 No. While assisting disaster victims is an approved cause, the AVP should not approve this request, for two reasons. First, under this policy, a request for the Postal Service to sponsor employee participation should be generated by an interested employee or group of employees, not by the representative of an outside group (in this case, the minister). Second, even though there is nothing religious about collecting clothing, the Postal Service’s participation in an activity sponsored by a particular religious denomination may be perceived as favoring that denomination, even if no favoritism is intended.

Q21 Suppose a clothing drive similar to the one described above is organized by the (fictitious) “Interfaith Council,” an ecumenical association of churches, temples, and mosques in the local metropolitan area. The Council’s chairman contacts the Postmaster to ask if the Post Office will help. Could the Postal Service participate?

A21 No, for the reasons provided in the previous answer. Even if this request was made by a postal employee interested in participating in the Interfaith Council’s clothing drive (and not by a member of the Interfaith Council), the Interfaith Council is considered a religious organization, despite the fact that is it non-denominational, because it is comprised of religious entities.

Q22 Suppose a clothing drive similar to the one described above is organized by the (fictitious) political association called the “Green Party Millennials.” May postal employees participate under this policy?

A22 No, the HQ Officer or AVP must not approve this request. Again, although there is nothing inherently political about collecting clothing, participating in a clothing drive sponsored by a political association that is affiliated, or widely perceived as affiliated, with a specific political party may appear to be an endorsement of or favoritism toward that party, even if none is intended. However, employee participation in eligible community service activities sponsored by non-partisan organizations may be approved.

Q23 Suppose the (fictitious) “LGBT Crisis Care Center” organizes a 5-mile walk to benefit cancer victims in the community, and three postal employees have requested Postal Service sponsorship of their participation in the walk. The registration fee is $30 per person. May the HQ Officer or AVP approve this request?

A23 Yes, the HQ Officer or AVP may approve the employees’ request to participate in this walk if there is adequate funding in an existing budget. The amount of the per person registration fee — $30 — indicates that it is intended to cover the actual cost of participating in the walk, not to serve as a direct charitable donation. And, because the Postal Service prohibits discrimination on the basis of sexual orientation, supporting an LGBT organization’s efforts to assist all cancer victims is not considered controversial under 333.721c. It is important to remember, however, that the CSAP prohibits the Postal Service from promoting the political agenda of any organization. An event or project must serve an approved cause, such as promoting wellness or relieving hunger, and not be designed to further a particular political agenda.

Q24 Suppose a local health clinic widely known for performing abortions asks the Postal Service to buy a table at its fundraising dinner. May this request be approved under the CSAP?

A24 No. Although abortion is legal, it continues to be an issue of impassioned political debate. While the Postal Service has no policy for or against abortion, its mission is to help bind the nation together, and appearing to take a position one way or another on such an issue would detract from this mission. In addition, this is not an appropriate CSAP request because it is not a request seeking approval for employee participation in a community service activity.

Q25 The Bigtown Community Library sponsors an ongoing book drive for which donations can be made at collection boxes in locations across town. A postal employee submits a request to place a book drive collection box in the Bigtown Post Office’s customer parking lot. May the AVP approve this request?

A25 No. Participation in a book drive may only be approved under CSAP when solicitations for donations are only made to postal employees, and when the collection of donated books will be conducted in an employee-only area of the postal facility, not in an area open to the public.

[Revise the titles and text of 333.76, 333.761, and 333.762 to read as follows:]

333.76 Requesting Approval for an Activity Under This Policy

333.761 PS Form 3337-A

PS Form 3337-A, Community Service Activity Participation Request, must be completed and submitted far enough in advance of the event/activity to provide sufficient time for the DM and AVP or HQ Officer to fully consider the community service activity request. It is recommended that requests be submitted to the DM and AVP or HQ Officer at least 30 days prior to the event/activity. The process for requesting approval is set forth in 333.714, and repeated in the “Instructions” portion of PS Form 3337-A. Participation in community service activities must be approved through this process.

Note: PS Form 3337-A (January 2017) replaces PS Form 3337-A (July 1999; updated through July 2014). The form is available on the Postal Service Intranet at http://blue.usps.gov/cpim. PS Form 3337-B has been made obsolete.

333.762 Sample Completed PS Form 3337-A

A sample completed PS Form 3337-A is provided as Exhibit 333.762. Direct questions about the information requested on the form to the Ethics Office at 202-268-6346 or ethics.help@usps.gov.

Exhibit 333.762

Sample Completed PS Form 3337-A – Page 1