Archive for the ‘Regulatory Impact’ Category

Coloring inside the Lines – Designing Business Communications in Highly Regulated Industries

Wednesday, November 13th, 2013
From Don Quixote by Miguel de Cervantes.

From Don Quixote by Miguel de Cervantes.

Most designers look at regulations the way that Don Quixote looked at windmills – as an adversary that must be defeated or circumvented.

In fact, regulations are just one of several boundaries on any designer of business communications. Designs are also restricted by:

  • Corporate Identity Guidelines
  • Postal Regulations
  • Production Processes

And just as windmills are not giants, boundaries don’t need to be the designer’s enemy. In fact, identifying these factors in advance can help to focus attention on the goals of the design and also apply a filter to the process of finding solutions. The ability to understand and design for these constraints can actually become a strategic advantage for the designer.

Do you need to be an expert on every regulation? Cam Shapansky, Partner at Canada-based marketing agency Blue ID says “I don’t think the designer should become the regulatory expert, but we’ve always tried to view the regulators as a friend.” At the end of the day, compliance departments and corporate counsel exist for a reason – they are the legal experts. What is critical is that designers understand when they are working with a communication that is subject to regulatory compliance and that they engage the appropriate experts as early in the process as possible. Some designers may be tempted to simply lift-out the regulatory language that is currently used. This is a problem for several reasons; first, the product or business changes that were the catalyst for redesign might have negated the need for specific disclosures. Second the regulations (or cited regulatory agencies) may have changed or be pending change – recent examples include the renamed FINRA (replacing NASD in the footnotes of your U.S. brokerage statements) and the newly formed Consumer Financial Protection Bureau or CFPB. Third, the company’s “compliance culture” or interpretation of the regulations may have shifted since the last time the document was updated. Some companies take a very conservative approach, erring on the side of legal protection to the corporation at the cost of customer experience. This can have a major impact on the design process as well as the design itself.

Another way that companies differ in their interpretation of regulations is in the placement of compliance messaging according to Michael Ellison. As the president of Corporate Insight, an analyst firm that uses live accounts at leading financial firms to benchmark communications across all major channels, Ellison reviews a lot of statements. “Some firms dump several paragraphs of legalese onto one page in very small type, creating a dense, uninviting reading experience that adds no value to the relationship. Others sprinkle the required language throughout the document. While still dense legal-speak, the language is at least a little easier to understand since it’s presented in proper context. A third – and in our view, optimal – approach transforms regulatory disclosures into readable, plain language, presenting this required text in a way that is not distracting to the reader.”  .

Progressive companies combine “point of need” messaging with plain language disclosures to minimize complex legal language and make sure that key information is placed where it is most useful to the reader. Some language may still be clustered in one area of the statement if it is general information that is not frequently referenced. According to Shapansky, “We consider the meeting with corporate counsel to be one of the most important meetings we have with any client. You know within the first 30 seconds what type of regulatory interpretation the company is going to follow and whether they are progressive or not. “

Working directly with a firm’s compliance expert provides a much-needed opportunity to advocate for innovations that make the language and positioning more customer-friendly. Sometimes the boundaries need to be pushed and interpretations need to be challenged for the benefit of the customer – and ultimately the corporation as well. Often in challenging specific compliance “rules” it is determined that they are not rules at all but simply “guidelines” defined by some long-retired employee of years gone by.

In designing business communications, you must have a strategy for dealing with the boundary conditions you face. Will the design process be based on rigid instructions or will there be a dialogue? Will the process lean toward the customer or toward a bureaucratic norm? Will you color well within the lines or will you color right up to the outside edge of the line?

Keys to Success:

  • Understand the current interpretation. Why was the regulatory language handled in this particular way? Has the corporate or regulatory climate changed?
  • Understand the corporate culture. Do they take a conservative position or a progressive position? Do they actually have a position or are they just doing what they’ve always done?
  • Make your case for any requested changes. Will your approach have a significant positive impact on customer experience, cost or risk exposure? Can you back your claims up with competitive benchmarks or research?
  • Provide several options. There may be more than one way to make improvements. Don’t end up with the status quo, legalese interpretation because you weren’t willing to compromise.
  • Engage with compliance representatives in person (and have your corporate sponsor on board with your recommendations first.) Remember, it’s easy to say “no” in an email. It’s much harder face-to-face.
  • Document the discussions and factors that drove the decision to take a particular approach. This will help to make the decision stick and avoid revisiting issues multiple times when and if new people join the project.

Most importantly, remember that regulations are intended to inform and protect the customer.  They also protect the corporation from potential liability.  Regulations are not the enemy of design, they don’t need to be defeated or circumvented. They need to be understood and implemented in a way that serves the intended purpose – and the same could be said of any portion of content in any information design project. Once you learn enough to color inside the regulatory lines you’re much more likely to be able to influence where those lines are drawn.


Elizabeth GoodingElizabeth Gooding is the President of Gooding Communications Group and editor of the Insight Forums blog. She writes, presents and provides training on trends and opportunities for business communications professionals within regulated vertical industries.

Jell-O, Healthcare and the New Normal

Wednesday, January 16th, 2013

physicians and hospitalsRunning a hospital or healthcare practice is already labor and capital intensive, highly regulated and impenetrably complex. The Affordable Care Act and the growing trend toward consumerism has added constant change to the list of industry challenges. While the ACA itself is the law of the land and implementation is moving forward, the foundational elements to be implemented are as firm as warm Jell-O. Change is the new normal:

  • States may or may not expand their Medicaid programs;
  • Health Insurance Exchanges (HIX) may be set up by states or by the Federal government in certain states, and the Federal HIX implementation structure is not fully defined;
  • Accountable Care Organizations (ACOs) are being formed and tested in near real-time;
  • Definitions of Essential Health Benefits (EHBs) can vary by state and guidance is required;
  • The “standard” 8 pages format for the newly mandated Summary of Benefits & Coverage (SBC) can now be any length determined necessary by insurance companies (Note: the purpose of this new, somewhat redundant, document was to provide a standardized plan comparison for consumers.)

Provider’s biggest concern may be potential changes and interpretations surrounding “Necessary Care.” According to the Journal of the American Medical Association, “care that did not show a proven health benefit, and where a less costly alternative was not used,” accounted for between $158 billion and $226 billion in 2011. Proposed regulation around necessary care shifts financial risk to doctors and hospitals and this, along with other regulations and stricter Medicare compliance requirements, will require investment in Electronic Health Records (EHR) and other major infrastructure upgrades that smaller providers are not equipped to fund.

The combination of independent providers’ flight from risk, a need to dramatically reduce costs and increased capital requirements is driving the next big source of change: Mergers and Acquisitions.

Market consolidation

fish eat fish

The pace of consolidation is mind boggling: the annualized number of hospital acquisitions or mergers nearly doubled between 2009 and 2012. Plus, physicians are merging with health plans and hospitals, hospitals are merging with hospitals and long-term care providers, health insurers are investing in hospitals and physician practices. Not to mention non-provider consolidation in biotech and pharmaceutical manufacturers, disease management companies and all along the healthcare supply chain. In an interview with The Huffington Post, Robert Laszewski,  president of Health Policy and Strategy Associates referred to the M&A climate in healthcare as an arms race in which the players are merging into bigger entities in hopes of restraining their own costs and grabbing larger shares of the markets.

According to PWC’s Healthcare Executive Agenda consolidation is not a panacea and even small healthcare mergers carry a lot of risk. We’ve seen the same thing in the merger-prone print industry – nearly two-thirds of deals do not meet pre-merger expectations. This lack of stellar success is not likely to stem the tide of mergers; however, it does present many opportunities for print service providers and industry consultants to make these newly consolidated entities more successful. Here are a few thoughts:

  • While individual providers and provider groups have low volumes of communications, larger merged-entities have volumes that are more attractive for outsourcing.
  • Newly formed entities have redundant documents and systems that need to be unified or eliminated in order to gain the sought-after costs savings from the merger. Consultants and Outsourcers can help to meet those needs more quickly.
  • The ability to consolidate volumes, processes and technology allows outsources to deliver immediate savings from house holding, postal optimization, white paper processing and electronic services such as electronic payment and presentment.

What needs to happen after a merger? Plenty of situations where service providers can add value:

  • Determine brand strategy. Research demonstrates that capital markets respond more favorably to brand strategies that involve combining elements of the two companies than strategies that replace one entirely or leave both untouched. This requires an analysis of the strength of both companies.
  • In parallel with re-branding considerations, a business communications audit needs to be performed to identify the people, processes and technology used for generating business documents. This audit should generate documentation on current processes and recommendations for leveraging the best practices within each firm, the combined volumes of the merged firms and eliminating redundancies.
  • New branding (and likely new regulatory language) will need to be incorporated in the systems that are proposed to be maintained going forward. Efficient implementation will typically require an additional analysis and redesign step to create document standards and streamline implementation.

The newly merged company will likely also be evaluating their supply chain; eliminating vendors or “right-sizing” with vendors that fit their new status as a larger organization. The ability to support these firms with the analysis and streamlining processes makes it more likely that you will be considered for additional outsourcing opportunities rather than dropped from the vendor list.

While it would be prudent for these companies to go through a detailed pre-merger fit and synergy analysis from both a financial and a customer perspective – most often the customer and customer communications strategy is in that “warm Jell-O” mentioned earlier. The opportunity to help companies evaluate these issues pre-merger or immediately post-merger can be of huge benefit in achieving the hoped-for cost savings and also maintaining market share by communicating effectively with customers and making sure the bills get paid amidst the merger madness. Let’s call that preventative care.

The bottom line is that if constant change is the new normal for health care providers, there will be constant opportunities for companies who can help them deal with those changes.

Editor’s Note: Additional information on changes in the Health care industry is available from our sponsor, Canon Solutions America. See the PressGo! Industry Guide to Healthcare.


Elizabeth Gooding


Elizabeth Gooding is the president of Gooding Communications Group and the editor of helping clients in highly regulated industries—and the service providers they depend on— to optimize the designs, processes and production technology used for multi-channel communications.

Health Insurance – Change Brings Opportunities

Thursday, December 13th, 2012

It’s fair to say that the business model for health insurance is in the process of being completely redefined by the Patient Protection and Affordable Care Act (PPACA or ACA). Health insurers can expect to spend the bulk of 2013 getting ready for the new post-ACA marketplace. How far reaching are these changes? Well, they impact critical factors like:

  • Who insurers can sell to: individuals in addition to groups.
  • Who insurers must sell to: no ability to deny coverage for pre-existing conditions.
  • Where they sell their products: new Health Insurance Exchanges (HIE) in addition to the usual channels plus new retail branches.
  • How they can sell their products: products offered through exchanges must conform to one of 5 standardized options.
  • How they can price their products: they must devote 80% (in some cases 85%) of premiums to actual customer medical expenses leaving only 15% to 20% for all administration and overhead.

In addition to the changes that are mandated by the plan, there are many changes that just naturally flow from adapting to a consumer-driven market. In 2011 approximately 50 million people – or about 16% of the US population – had no health insurance coverage or eligibility for government sponsored health programs. In 2014 approximately 60% of that population is expected to purchase private health insurance coverage – that’s about 30 million new customers. In addition, another 17 million customers may come on the books as states expand Medicaid eligibility to more low-income Americans since most states contract Medicaid coverage to private insurers.

Insurers are trying to turn their marketing and sales organizations into retail operations to tap the consumer market. Like retailers, they are trying to leverage data on their customer base to drive effective marketing and communications programs. Since, other than marketing Medicare supplement programs, most insurers have had little or no consumer marketing experience they need help in this area. Compounding the problem, according to PWC, this new insurance market is made up of consumers who are likely to be less educated and many will need material in a language other than English.

Since many of these new insurance consumers have never enrolled in a health plan before, they are likely to shop for health insurance they way that they would shop for any other major purchase like a home appliance or a car – by seeking out a familiar brand. To become top of mind before these people enter the market, insurers are investing in a wide array of advertising: TV, radio, web, print and billboards to build awareness. Direct mail, email and mobile marketing will only increase as new products become available and market data is refined.

But the retail transformation goes beyond branding, insurers are opening branches where consumers can learn about insurance options and buy on the spot. In May, Horizon BCBS announced that they would be opening a new retail center in New Jersey and Blue Shield of California recently opened a “Blue Shield Store” inside of Lucky’s Supermarket in San Francisco. These are two of several retail store-fronts in 5 or 6 states with more to come in 2013.

These retail operations will naturally need to be staffed with knowledgeable people and supported with kiosks and other technology but, they will also need printed collateral, the ability to order and manage collateral across locations and the kind of seasonal and tailored signage seen in the best branch banks and retail stores.

I’ve skimmed the issues affecting health insurers and haven’t even touched on the impact to health care providers – but I think you can see that this is a market in transition. And where there is transition, there is opportunity. It may be difficult to get the attention of insurance executives with everything on their plate, however, if you do get their attention and have solutions to help them market more effectively and efficiently to consumers while driving down the costs of servicing their insured members – you could be busy for years!


 Elizabeth Gooding is the President of Gooding Communications Group and the Editor of the Insight Forums blog. She covers key issues affecting business communications in highly-regulated industries.




Editors Note: White papers and podcasts on the impact of the ACA on business communications are available on Océ PressGo!:  a business development program for Océ customers.



Paper Legality Laws; Coming to a Continent near You

Wednesday, June 22nd, 2011

Over the past few years, discussions surrounding how legal paper sourcing decisions are made by print buyers have received less and less attention from the press. This doesn’t mean that the issue has melted away; it merely means normalization of the process has relegated it to the board room and to the senate committee. However that could change based on worldwide activities of a similar fashion. In other words, the race is on.

In a mere 22 months if you print on paper anywhere in the European Union (EU), there will no longer be a choice. Verified legal timber product sourcing, including pulp and paper, will become law.

Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 lays down the obligations of operators who place timber and timber products on the market – also known as the (Illegal) Timber Regulation counters the trade in illegally harvested timber and timber products through three key obligations:

1. It prohibits the placing on the EU market for the first time of illegally harvested timber and products derived from such timber;
2. It requires EU traders who place timber products on the EU market for the first time to exercise ‘due diligence';
3. Keep records of their suppliers and customers.

The Regulation covers a broad range of timber products including solid wood products, flooring, plywood, pulp and paper. Interestingly though, not included among a few other products such as rattan and bamboo are recycled products and printed papers such as books, magazines and newspapers.

The EU has chosen their battles just as the US has with the now familiar US Lacey Act. By excluding printed matter (for now) but including pulp and paper, the EU’s Timber Regulation leapfrogs Lacey in that European printers will no longer be at will to purchase paper without regard for legal harvests, specifically aimed at imports as of March 2013.

The Parliament of the Commonwealth of Australia Illegal Logging Prohibition Bill 2011 is still in the consultation phase, but is written so vaguely that if passed in its present form, is sure to create a (common) wealth of issues. For now, we have to take a wait and see approach. Taking their Bill with a grain of Aussie salt, I wouldn’t expect to see it passed anytime soon.

As a side note in its “Comments from the Government of Canada on Australia’s Draft Illegal Logging Prohibition Bill 2011”, the Canadian government is not amused. On May 6, 2011 the Secretary of the Senate Standing Committees on Rural Affairs and Transport wrote; “In particular, Canada is concerned that the Bill may lead to a requirement (whether explicitly stated or implied) for Australian importers to conduct risk assessments (or the ‘timber industry certifiers’ to do so on their behalf) on any unprocessed or processed timber products imported into Australia. Such a requirement would be particularly onerous for complex processed products made of timber sourced from multiple suppliers…” (like paper merchants and printers).

Which brings us back to the Lacey Act and its implications in the paper and printing industry here in the US. For the time being it seems like no movement on implementation pertaining to US-based paper mills and printers is imminent. That said, with all of the activity on other continents, one has to wonder.

Roll Your Eyes or Prepare for April 17 Postal Increase?

Tuesday, April 12th, 2011

Julie Sullivan marketing VP WildeOn April 17th, there will be another postal increase for some mail categories. As a direct marketer, you can choose to do one of two things:

1. Roll your eyes and feel defeated by yet  another price increase, certain that direct mail has become cost-prohibitive. OR

2. Scratch your head and reflect on ways to optimize your programs and actually save money despite the postage increase.

If you, like me, opt for the silver lining approach, let’s explore four smart and easy ways to decrease your direct mail spend and increase your response rates. Talk about a win/win proposition!

  1.  Segment Your Data.  By segmenting your database, you’ll be able to quickly discover buckets of opportunity ranging from your most profitable customers to your highest potential prospects. Allocate your marketing dollars wisely, and don’t waste your budget on messages that will fall on deaf ears.
  2. Craft Relevant Messaging. As a direct marketer, you goal is to illicit response. Not only do you need to find the right audience, you also need to hit them with a relevant message that will get them to act on your offer. Incorporating strategies such as personalization and human behavior response triggers into your copy and design can improve your response rate and ultimately increase revenue.
  3.  Digitize Your Print. Use technology that will transfer your one-sized-fits-all communications into meaningful conversations. Through business rules assigned to your program, variable digital print can take hundreds of variables and make them come alive into a personalized message for your target audience. Less volume and higher response can validate the digital print ROI.
  4. NCOA Your Mailing List. An upfront investment in NCOA (National Change of Address) could save you sometimes thousands on undelivered mail. Use this updated data with correct mailing addresses to cleanse your database and maintain a high quality list.

I received a timely example in the mail yesterday that brings home the point I am trying to make. A catalog called “Your Electronics Source for Engineering Solutions” was sent to me but with the title of a position I held two years ago. Had I left Wilde, this irrelevant catalog would have never come to my attention. Lucky for them, I’m still at the same company. But unlucky for them, I’m not in the market for Extra Rugged Sealed Circular Connectors or Round Pin Fin LED Heat Sinks anytime in the near future. Money, in my opinion, not so well spent.

Important Advice to all FSC Certified Printers

Friday, March 4th, 2011

Recently, the Forest Stewardship Council released their revised FSC-DIR-40-004 document, containing a series of advice notes which every certified printer (and converter, and merchant, and broker) “should have” received through their certifying body (CB). Included in this document is Advice Note ADVICE-40-004-03 which deals with the ability for printers to FSC-Label certain classifications of paper.

A synopsis of the official background for ADVICE-40-004-03 which is contained in FSC-DIR-40-004 and is titled: “Reduced labelling threshold of 50% for chip and fibre based products” states in effect that when the new Chain of Custody standard was approved in November 2007, a labeling exemption threshold of 50% (certified material, the balance being “controlled”) for chip and fibre based products under a percentage (or transfer) system was maintained by means of an Advice Note. (All solid wood products such as or made from lumber, plywood or veneer had to implement a 70% minimum at that time which is still in force today).

The FSC would have loved to enforce the conformance for all chip and fiber products which includes all paper and paperboard to the 70% minimum back in 2007, but the mills pushed back and reduced labeling threshold was born. This advice note now the latest twist added to the existing requirement as a way to definitively force the mills to conform with the intended 70% minimum within five years (their other option being to move to a Credit System).

The official advice note can seem quite cryptic:

  1. FSC certificate holders may request authorization from their certification bodies to continue labelling chip and fibre products based on a reduced labelling threshold of 50% until 31 December 2015
  2.  Authorization shall only be granted for those product groups with chip and fibre components registered as being commercially produced based on a labelling threshold of 50% before 01 April 2011.
  3. Certificate holders operating a transfer system that have not registered their product groups can also label products based on a labelling threshold of 50% in case they are able to demonstrate to their Certification Body that the material they receive has already been registered by a previous company or the material was received with an FSC on-product label.
    a. In the first case, sales and delivery documents issued by the supplier shall include the additional claim “registered” (e.g. “FSC Mixed 50% registered”);
    b. In the second case, the certificate holder shall retain evidence that the product was received with an on-product FSC label (e.g. packaging or product sample).
  4. Certificate holders interested in the product registration shall submit the following documentation to their Certification Body until 31 March 2011:
    a. A list of product groups with products labelled on the basis of a 50% threshold, using the template provided in Annex A of this Directive;
    b. Copies of sales invoices for the registered products in each listed product group as evidence that they have been commercially produced.
  5. Certification bodies shall upload the approved registration form into the FSC database following the procedures to make it publicly available. No new product groups can be added to this list after 31 March 2011.
  6. Product groups registered by certification bodies according to this advice shall be in compliance with a labelling threshold of 70% as of 01 January 2016.

NOTE: Companies that do not comply with the requirements of this advice are not eligible to label FSC products based on a 50% threshold as of 01 April 2011, and therefore shall apply a labelling threshold of 70% from this date onwards.

“So what does this mean to me?” is a natural question that every FSC certified printer should be asking their CB if they don’t know already.

Let me put it in real-life terms most printers can understand. The majority of paper mills use the Credit System which effectively renders a product the equivalent of 100% certified. This advice note does not pertain to any inputs purchased from these mills or their merchants which are received with a claim of “FSC Mixed Credit”.

There are however a handful of paper mills using the Percentage System for calculating certified content for their products. Generally speaking, none historically have been consistently sold at a minimum 70% level, which necessitates conformance with this requirement in order to maintain the status quo for the next five years. (Most on the market today range between 50% and 60% certified material, sold for example as “FSC Mixed 50%”).

This “transitory” exemption allows for paper that contains at least 50% certified fiber (but less than 70%) to still be eligible for the FSC label up until January 1, 2016. The way the advice is worded in item 3 (above), you the printer are dependent on your supplier’s complete conformance. As long as your supplier either passes along the phrase “Registered” as part of the FSC Mixed XX% claim and/or; the product is received by you as an FSC labeled input; the product remains eligible for you to apply the FSC label. You may however have to provide evidence to your CB in order to gain labeling approval, which becomes another hoop to jump through.

Things to take into consideration are that first, there is a note within the advice note which states: “The exemption detailed in this advice is specifically related to the eligibility for labelling FSC products and not to the eligibility of producing or selling products with an FSC claim on invoices.” Therefore because not all merchants may apply for this exemption because it technically doesn’t affect them, the product could be rendered ineligible if sold by them without them registering and without an FSC label (FSC labels, even for paper in cartons, are an option, not a requirement).

The easier way is to register for the exemption with your CB. This is a one-time deal and should be a very simple process for most printers. The information required is to simply furnish your Product Group as defined on your Product Group Schedule for FSC Mixed Products (i.e.;FSC Mixed Printed Materials) on the form (which should have been) provided by your CB along with an X in the appropriate space denoting “Use of the labelling threshold of 50% until 31/12/2015” along with a few copies of invoices for said Product Groups that you have sold (i.e.;FSC Mixed Printed Materials).

Do it now and save yourself a headache in the future.

Vic Barkin

How Responsible Sourcing Will Impact Printers in 2011

Friday, January 21st, 2011

If you were in the storefront printing industry in the early-to-mid Eighties, the sign “We Accept Disks” means something to you. It was the beginning of the digital and “desktop” printing revolution. “We Accept Disks”. It meant you had a PC and/or maybe a MAC, and would accept customer floppys in order to print out copies to paste up and shoot to a neg or output an analog poly plate, or maybe run copies (not files) on your copier. But it didn’t mean there was any compatibility with what your clients were bringing in. All you knew was that you had to do it because everybody else was.

Let’s get one thing out of the way right now. This is not going to be a crystal ball article. The rhetoric surrounding “green”, “sustainability” and “corporate social responsibility” has cooled a bit. This means we are now in the normalization phase. Between 2005 and 2008, literally everything gained a greenish tinge. It’s the same with every standard business practice bubble. First there were the early adopters, and then market acceptance comes along. This is typically followed by market saturation, and finally normalization. Many shops claimed to be a “Green Printer”. Maybe you got FSC certified, increased your recycling efforts, switched to low VOC chemistry or replaced or upgraded offset equipment, or implemented higher efficiency digital.

2009 capped the trend by becoming the year of the “green printing trade show”. Again, everything had a greenish tinge to it. It didn’t matter what the product or service was. It was either “green” or “sustainable”. Then the inevitable happened. The Six (or Seven) Sins of Greenwashing hit the print industry airwaves and uncertainty about the message and its credibility crept in. Trade shows in 2010 had a diminished green presence. Not that it completely disappeared; Green now has earned a secured place in Print’s message. Now the FTC is releasing new green claim guidelines.

So here we are in 2011. Responsible sourcing/procurement is fast becoming the driving realization that encompasses everything green and sustainable. Business Green offers 11 (as in 2011) things to look for in the next 12 months. Number 7 is “Ethical consumer spending will keep rising”. To quote a portion of the Business Green statement: “Every indication suggests this market will grow substantially this year even as other areas of the economy falter. It is time to stop treating green industries as a niche and appreciate them for the robust and fast-growing success stories they are”.

Let’s take a closer look at what this means to the printing industry.

Paper is most likely to be thought of first. Chain of Custody certification, whether it’s FSC, SFI or PEFC puts third-part verification of at the very least legal and ethical sourcing. The credibility of the certifying bodies, who themselves are validated by independent accreditation organizations provides transparency as well as credibility. Supplies, whether for offset, digital, or for infrastructure (janitorial, facilities) also have their certification and third-party certifying body counterparts.

Green computing is going to have a large presence this year as the IT industry takes sustainable computing mainstream. The Climate Savers Computing Initiative is a nonprofit group of consumers, businesses and conservation organizations dedicated to promoting smart technologies that can improve the power efficiency and reduce the energy consumption of computers.

Formalized waste-stream reduction strategies have become profit centers for many organizations. Harmon Recycling, a division of Georgia Pacific is one of many organizations offering full-service programs to both manufacturing and office environments. Everything that can be recycled should, including strapping, containers of all types and other shipping material. In short, a zero manufacturing and office waste program is more of a reality now than ever as the reclamation industry matures.

A life cycle assessment (LCA, also known as life cycle analysis, ecobalance, and cradle-to-grave analysis) is a technique used by organizations to assess each and every impact associated with all the stages of a particular process from raw material sourcing through materials processing, manufacture, distribution, use, repair and maintenance, and disposal or recycling). LCA’s can help avoid a narrow outlook on environmental, social and economic concerns which can validate both responsible sourcing and responsible disposal methodology.

Then there are all the other infrastructure improvements that also have their ethical, responsible and or sustainable components. This includes everything from buildings, HVAC, lighting, logistics and production equipment, to transportation and facilities management operations.

The end-game is that professional purchasers are embracing responsible sourcing. Organizations like The National Association of State Procurement Officials, the Responsible Purchasing Network, and The International Society of Sustainability Professionals are serious about responsible sourcing and many options are considered in choosing suppliers, based at least in part on their ethical sourcing policies. Don’t be caught out in the cold because you cannot quantify and provide objective evidence pertaining to where your raw materials, products and services came from, and where your waste and by-products are going.

Responsible sourcing is the new green.

Vic Barkin

ISO versus the FTC on Post Consumer Waste

Monday, November 15th, 2010

Ever heard this one before? A print buyer sends the specs for a job specifying “recycled paper”.

We’re talking about recycled “content” here, which is simply any percentage of the paper made from fiber (paper) that has been diverted from a waste stream. This is further broken down into pre- and post-consumer waste components. Commonly, but not always, it’s only the post-consumer portion that’s reported on invoices or printed on the piece its self.

Now, especially since the FTC’s proposals for their new Green Guides have hit the streets, many potentially-effected entities are waiting for the storm concerning the definition of post-consumer waste. This may not seem like a big thing, but it is.

It’s more important than ever now to define “recycled content”. For instance, did you know that under the FTC’s current as well as their proposed guideline, a specific edition of printed matter, say a magazine issue, can be considered either pre-or post-consumer waste depending on where it lives when it’s recycled?

Post-consumer reclaimed/recycled/recovered waste/fiber (PCW or PCRF) definitions are going to become a touchy issue in the coming months. Once the FTC codifies their definition, it will become the de facto standard, and no matter which way the wind blows, the FTC will wind up continuing to put their definition at odds with the interests of others.

The current FTC Guides provide that marketers may make a recycled content claim from materials which have been reclaimed either during the manufacturing process (pre-consumer) or after consumer use (post-consumer). This sounds pretty straight-forward.

Furthermore, the FTC aligns their definition of PCW with that of the EPA’s: “Fiber such as paper, paperboard, and fibrous materials from retail stores, office buildings, homes, and so forth, after they have passed through their end-use as a consumer item; all paper, paperboard, and fibrous materials that enter and are collected from municipal solid waste.”

ISO 14021 however defines post-consumer as: “Material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product, which can no longer be used for its intended purpose. This includes returns of material from the distribution chain.” A definite difference of opinion.

When it comes to paper certification schemes, under current standards, both FSC and SFI subscribe to the FTC/EPA definitions (SFI actually requires alignment with the FTC rulings no matter what), however PEFC adheres to the ISO definition. That’s where the fun begins.

In response to the new FTC draft, many mills, recyclers and other groups have commented on the wisdom of the ISO definition noting that the FTC Guides should incorporate those definitions of post-consumer recycled content because competing definitions currently cause consumer confusion.

The reality can be summed up to intent. Is the intent that all material in its finished form has an equal recycled value no matter whether it has reached the end user/point of intended use or not? One can certainly argue that a publication which is remaindered (i.e.; never distributed) being exactly the same product as one that was read by the end-user, has exactly the same value in the recovery stream.

We don’t know as of yet which way the FTC will decide to go, but one thing is certain. Somebody’s not going to be happy. If the Guides are published as proposed, does it mean that merchants and printers need to watch all imports for the stated PCW content because they adhere to the ISO definition? Or will international mills have to adjust their PCW standards for exports to the US? It does present an interesting conundrum.

If FTC does adopt the ISO definition what happens to the FSC standards? Will they lower them to fit? Probably not, partially because of one interesting development; FSC released new trademark standards this past spring. The recycled mobius which used to convey the PCW content now conveys all recycled content. I find this a highly interesting development in conveying the message that reclaimed materials as a whole are equally valued.

As a final comment and case study, NewLeaf Reincarnation Matte was first released as a 50% pre and 50% post-consumer waste product (now 60% PCW). Under FSC standards both then and now, in order to use an FSC Recycled label there had to be at least 85% PCW, which meant that although 100% recycled, the FSC Mixed label with a 50% in the mobius had to be used for this product. Now under the new standard, though it’s still an FSC Mixed product, the mobius can state 100%. As Arte Johnson used to say, “Verrry Interesting…”

The First Rule of Internal Auditing

Monday, November 1st, 2010

This is an open letter to all the wearers of many hats out there.

If your organization happens to be ISO, SGP, FSC or SFI certified, or even if you’re not formally certified to anything, but still subscribe to some type of formalized quality management system framework, you may think this article’s not for you, however hear me out before you decide.

If your organization doesn’t formally subscribe to a quality management system of some type, this article’s definitely for you as the benefits are infinite. It ultimately saves the organization time, money, effort, money, energy, money, resources, money and money.

Quite frankly, like so many other things, the 80/20 rule applies here. In this case, eighty percent of the organizations I visit do not implement internal audit (IA) protocols for their processes, and of the twenty that do, eighty percent of them have no clue how to do it correctly.

Regardless of whether there is an external certifying body that requires it or not, the only way to truly validate conformance to any process is to impartially audit it. Like a financial audit, process auditing is a skill using a rules-based approach. The key is to ask the right questions in a consistent, controlled and meaningful manner in order to discover any underlying nonconformities which may either consciously or unconsciously exist.

The first step is to be able to measure any process from a procedural perspective. No standard? No measurement. No procedures? No control. Anything can be evaluated, verified, validated and/or measured. A procedure can be as simple as how to answer a phone to how to produce a job by breaking down each component part, to how to measure customer satisfaction. It can be statistical, empirical or documentary.

Also, let’s not confuse process or product development, realization, verification and validation with internal auditing. Management and staff directly involved or affected by or from any process activity should always be involved with the procedurally-related activities pertaining to that process. That’s not what we’re talking about here.

Internal auditing is an intermittent activity that should be planned to be enacted at least annually to evaluate every process in the enterprise. Some processes which are more critical than others should be internally audited more frequently, sometimes quarterly, and of course immediately upon reoccurring issue identification such as multiple product non-conformities or customer complaints.

Management needs to ensure that objective guidelines are established based on procedural requirements. Any procedure can be turned into a question for these purposes. A procedure stating that “All Author Alterations shall be reviewed by the CSR in charge” can be turned into the question “Have all AA’s been reviewed by the CSR in charge?” In this way a manageable set of questions applicable to the process can be asked in an objectively interpretable manner.

Audit sampling is also an important aspect of meaningful IA’s. They should be random, yet should represent the breadth of range of the products involved. In cases where a repeatable process is in play, a smaller sampling which is representative of the overall volume is sufficient. Where more variables exist, the audit sample should be larger. It could be as much as 20%. Some auditing standards also use the 8/10 of the square root of the sum total rule. As an example, if you have 1000 unique orders, you would internally audit 25 of them.

Now let’s talk about internal auditors. They should first and foremost be “detail oriented”, articulate and diligent. There’s another term for this kind of person in general use, but this is a family-oriented column. Second and equally as important is that the internal auditor should have no responsibility within the process or system being audited. Case in point is that the CFO of an organization is a prime candidate to perform purchasing department IA’s (unless of course one of the hats the CFO wears is that of purchasing manager). The last point is one of objectivity. With a well-crafted internal audit checklist in hand, internal auditors should be able to validate any process in the organization impartially and with total objectivity. “Just the facts, ma’am”.

Once the IA has been completed, any non-conformances should be expressed in the form of a corrective action request (CAR). CAR’s should reference the specific procedure along with a description of the non-conformant issue(s). From there, management should investigate the causes by performing a root cause analysis (RCA). RCA’s in their simplest form ask why, five times, just like when a child asks why the sky is blue.

And finally, once the IA’s, CAR’s and RCA’s have been completed, it’s time to put together an action plan along with a resolution timeline which is followed up on my management. For issues needing immediate attention due to systematic failure, the timeline should be rather short. For procedural non-conformities which do not directly affect the outcome, a longer period of time is acceptable, but no longer than to be part of the review process during the next scheduled IA. In all cases the CAR should be re-evaluated and either formally closed or elevated.

These are the tops of the waves. IA implementation is just one tool in a total quality management/ continuous process improvement program. Implemented effectively, the end result is always an improvement over the status quo.

Vertical Stuff Transaction Printers Should Know

Monday, October 11th, 2010

A quick note on some regulations that are impacting transaction documents in the Financial Services Vertical:

1. Cost Basis Reporting

2. 401(k) Fee Disclosure

The Emergency Economic Stabilization Act of 2008 is best known for the $700 billion bailout provision – but also includes new requirements for financial intermediaries  to report adjusted cost basis  to investors and the Internal Revenue Service (IRS) for securities transactions. The stated goal of the legislation is to provide investors with the means to accurately report gains or losses on the sale of securities for their annual tax filings. However – a more realistic perspective would be that the government wants a way to ensure that investors are accurately reporting gains and losses (particularly the gains!) on their annual tax filings. In 2005, the IRS estimated that the US federal government was losing approximately $11 billion in tax revenues due to the failure of investors to accurately report adjusted cost basis information and it has likely gotten worse since then.

While adjusted cost basis will be required to be reported on the 1099-B, many firms are also preparing to include  it on customer statements so that their customers are aware of the tax consequences of their trading activity. At minimum, firms are preparing messaging strategy around this issue. This legislation will impact Equity holdings (brokerage) in 2011, Mutual Funds (held directly or through brokerage) in 2012 and debt investments and options holdings in 2013. The DTCC provides a good overview of the reporting requirements and open questions. This will make statements and possibly trade confirmations and 1099-B forms longer – significantly longer for firmst that do not currently report holdings at the tax lot level.

Next on the list of regulations making envelopes fatter is the US Department of Labor who will be issuing new guidelines in the next 30 days to require 401(k) plan sponsors (employers offering 401(k) plans) to provide plan-participants (employees invested in the plan) with more-detailed information on the fees and expenses associated with the investments in their retirement portfolios. While the legislation talks about the plan sponsors, in reality, the process changes will fall on the backs of the recordkeepers who support them – companies like Fidelity Investments, T. Rowe Price, Schwab, TIAA-CREF – who are the same companies dealing with the cost basis changes as well. Investment News is a pretty good source to keep on track of changes for the 401k market – however they are more concerned with the potential litigation aspects of the issue than the impact on customer communications.

What does this all mean to you? Well, if you are a service provider, this is a great opportunity to help your clients out with redesign and plain language services to minimize the impact of providing the new information. In situations like this, the impact on page count is a concern, but the phone ringing off the hook due to new and confusing information can be even more costly in the short term. If you don’t have the expertise in-house to provide this type of vertical market redesign and consultation – now would be a good time to find a partner because the regulatory changes aren’t going to stop any time soon. With the right partner – you have a chance to be a real hero to customers struggling with these regulations – and that’s the kind of relationship you want to build right?

So keep up with the “vertical stuff transaction printers should know” and have a real conversation with your next customer or prospect.

More Certified Paper Stuff? Really??

Monday, August 16th, 2010

As if you need more banter about FSC, SFI and PEFC, here comes yet another slew of mindless babble about paper certification. First however, I must digress.

I always tell my clients to look at the forests in which they live and find a grove over 100 years old. Although this is a generalization, for the most part, we screwed things up with our early logging practices when the supply was “limitless”. That said, this is now our collective legacy and our responsibility. No offence, but many of you have no concept of what our forests looked like before we got here. What’s occurring now in under-developed nations world-wide happened here a hundred or more years ago. Ok, now back to the drivel at hand.

What most people don’t realize is that there are two types of “certified” virgin fibers that can go into our paper. First is from managed (read third-party audited) forests. Second is what we’ll generically call verified responsible procurement, where the forests themselves are not audited, but the wood is confirmed to have been legally sourced, and basic environmental, social and local economic criterion are met.

Now listen very carefully; both go through a certification process of one type or another. Both are considered “certified” and both can be included in a Chain of Custody (CoC) certified product, because both can be traced back to their origin. Got it? Good!

Although there are philosophical differences between FSC, SFI and PEFC as to what constitutes good forest management, the purpose of this writing is not to discuss the merits of one certification system over the other, but simply to state that any management system is better than no management at all.

Let’s be brutally honest. If you are currently certified to anything, chances are it’s because you were told you had to be. Your clientele’s marketing and public relations folks are in the business of positive image and profitability (or at least accountability). Credibility and transparency are key components of that. Oddly enough they are also the main tenants of responsible sourcing and of CoC.

Look at a CoC label like you do the UL or CE label on your electronics. It’s a guarantee, a promise. To your customers it means that you voluntarily have someone looking over your shoulder as a partner to give them the assurance that, odd as it may sound; certified paper is actually verified to have been used in their certified product.

Did you know there are many papers out there that are available as either CoC certified or not depending on whether credits (based on equivalent Forest Management (FM) certified purchase volumes) have been applied? And that the non-FM certified portion still comes from certified procurement sources? Is it a perfect process? No, but until enough land is third-party audited to any kind of FM standard, it’s the best we have. Bottom line is that (and listen carefully) none of the fiber that goes into any CoC certified product comes from unknown or illegal sources.

Ok, back to the banter. So once again, there is FM-certified wood and there is responsibly procured wood. FSC’s responsible sourcing program is called FSC Controlled Wood (FSC CW). SFI’s version is called SFI Fiber Sourcing. The difference between the two is philosophical at best, although I know others would argue that.

Among other things, the FSC has made the decision not to sell FSC CW as a labeled product to end-users, but only as a component as an FSC Mixed CoC product. Although there is no such thing as a Controlled Wood label, when you buy brand of paper that is available as FSC certified upon request, but what you’re purchasing isn’t, the fiber is actually equivalent to the volume of FSC CW. The SFI on the other hand allows for the sale of Fiber Sourcing-labeled products to end-users, but this is not CoC certified (I’m sure that’s clear as mud).

One thing must be understood. If clients request CoC certified rather than simply certified paper, then SFI Fiber Sourcing products are not an option. Only SFI CoC, PEFC CoC or FSC CoC are. Case-in-point; Sears Holdings instituted just such a paper purchasing policy in November 2009. Many other private-sector, government and institutional organizations have also implemented similar policies. Just Google “paper purchasing policy” and see what pops up. Some say “certified” others say “CoC certified”.

So with all of this confusion what is the definition of “certified”? The (triple) bottom line is that even SFI Fiber Sourcing/FSC Controlled Wood certification goes through an in-depth risk analysis which includes among other things the reputations of the providers, the level of corruption in the region, as well as other aggravating factors.

High risk situations trigger third-party audits even under certified sourcing programs. As an example, based on historical environmental and human rights violations, this past April (the month), APRIL (Asia Paper Resources International Limited) had their FSC Controlled Wood certification suspended. Remember, this was not a CoC certification that was revoked, but simply a responsible procurement certification. What does that tell you about the bigger issues out there?

And finally as many of you know, pending expected legislation is the elephant in the room; the 110 year-old Lacey Act. Under the Lacey paper and print amendment it will be “unlawful to import, export, transport, sell receive, acquire or purchase in interstate or foreign commerce any plant taken or traded in violation of the laws of a US State or most foreign laws”. The reality is that Lacey as it pertains to paper and printing goes back under consideration on September 1, 2010.

Although not yet, eventually, it will become law, and when it does, any paper product is subject to at the very least confiscation upon even the accusation that the paper was illegally sourced. The scary part is that even if your supplier’s supplier is charged, you and your customers technically become confiscation-liable. And although CoC certified paper and to a slightly lesser degree, certified responsibly procured paper is not the end-all, it goes a long way in establishing “due care”. So in effect, oddly enough right now it is not illegal to purchase paper sourced illegally, but it soon will be.

If your customers are satisfied with your word, and they don’t require a licensed CoC (or Fiber Sourcing) brand to be printed on their material, then fine. But if they do require their suppliers to be certified everybody’s on a level playing field anyway. If you don’t believe me, go buy your next computer without a UL or CE label.

Changes to FSC Group Certification Rules Benefit Printers

Thursday, August 5th, 2010

For many smaller organizations, the cost as well as the amount of time required for the learning curve, procedural development and maintenance of an FSC certificate can be prohibitive. For years, the Forest Stewardship Council has had a program called Group Certification in place (FSC-POL-40-002), allowing organizations under different legal ownerships to band together under one certificate and share costs and resources by taking advantage of an economy-of-scale audit sampling program. This however this has been unworkable for most in the past.

The problem had been that program eligibility was limited to organizations having no more than 15 workers, or no more than 25 workers and annual forest product sales (i.e. printed material) of no more than $1,000,000 USD. This made certification unreasonable for many organizations as that kind of employee-to-revenue ratio was unrealistic at best. All of that has changed with a revised 5-year pilot program for group certification enacted by FSC-US which allows for any organization with less than $5,000,000 in annual revenue, regardless of employee count, to be part of a group certificate.

By utilizing a centralized group coordinator, multiple independent legal entities are able to share many of the basic procedural development and ongoing monitoring functions of certification without dealing with the learning curve and resource allocation required to do so separately. The net effect is cost and time reduction for each group member involved. This is similar to the Multi-Site certification program (FSC-STD-40-003) already employed by many organizations who legally own all of their sites. Virtually all FSC-certified mills, distributors and printers with multiple locations are currently certified under multi-site certificates and operate under the same type of framework as a group certificate.

Group certification has enormous potential benefits for at least three distinct types of groups in the printing industry. First are in-plants where the organizations do not compete with each other, yet have open lines of communication through either associations or proprietary list serves. Second are franchises in which each site is independently owned and conforms to a central office’s authority where the coordination function can be unified, and third are associations, whose members are organizationally connected and can band together for mutual benefit despite sometimes competitive relationships.

The primary requirement for any group is to first appoint a coordinator who can organize, develop, train and monitor the group’s activities. Member sites are subject to the coordinator’s oversight and must agree to adhere to an open and transparent process as a participant of the group entity. The group coordinator is responsible for developing procedural and operational templates for all of the participating sites for them to utilize and customize for their own unique usage requirements. Although each group member may have their own unique workflow and business rules, a collaborative effort can be made to develop systems that will work for the good of the all.

The group coordinator is required to perform initial internal audits of each member’s conformance as a precursor to certification to ensure workability of each site’s system, issuing corrective action requests where non-conformances are found, and working with violating member organizations to rectify and close out any outstanding issues. Once the FSC certificate has been awarded, subsequent annual internal audits occur during the course of each year, which are followed by certifying body site visits in which a representative sampling of sites (usually 20 to 25 percent of the sum) are audited every year.

For those unfamiliar, certifying bodies are the organizations accredited by the FSC to conduct day-to-day business activities on FSC’s behalf including, but not limited to, audits and trademark use approvals. Certifying bodies in the US are: American Green, Bureau Veritas, QMI, SGS, SmartWood and SCS.

As a requirement of certification, records of FSC activity must be maintained, collected and reported to the FSC through the certifying body in a summary format annually. This can be boiled down to each member organization’s total FSC activity without regard to client information should there be an issue with confidentiality.

Depending on the size of the group, the time required by the group coordinator for FSC oversight can vary. The development of procedures and data collection systems, along with training and initial internal auditing can be pretty intense, therefore the coordinator needs to be dedicated to the task. For a small group, as time goes on, the coordinator’s demands lessen. For a large group (potentially in the hundreds) the FSC coordinator’s activities can be closer to a full-time job.

Because the activities of each site affect the group as a whole, it is imperative (and required) that the coordinator has both the autonomy and authority through contractual relationships to enforce certification requirements. Each site must also have a designated site coordinator who acts on the group coordinator’s behalf, enforces FSC requirements at the site level, and complies with any requests made by the group coordinator in the course of his or her duties. Part of that authority is the ability of the group coordinator to suspend or remove any member at any time for non-resolution of conformance-based issues should they arise. The group coordinator is also responsible for collecting fees associated with certification from all participating sites, and for all coordination with the certifying body including obtaining trademark use approvals.

FSC group certification has huge potential. It’s already in use by forest land owners and other wood product manufacturing groups, sometimes with membership in the single digits (UMCFPG in Aitkin County Minnesota has 8), or the tens of thousands (Wisconsin’s MFL Program has 31,000 members) and has been proven to be a cost-effective solution across the board. The printing industry has not yet taken advantage of this system, but now that the maximum revenue level has been raised to a realistic level, the time is right to take full advantage of the situation.

Organizations no matter how loose or tight-knit who are interested in exploring this very realistic and workable option can contact me at, or can contact any of the certifying bodies listed at

USPS, PRC and AMA – oh my!

Wednesday, August 4th, 2010

On July 26th, Ted Kulpinski posted on “Fighting the Good Fight” in reference to the AMA’s fight against US Postal Rate hikes.  A number of people shared their perspectives on the lawsuit and related controversy.

The USPS has petitioned the Postal Regulatory Commision (PRC) to reject the AMA’s request. Jim Tierney at Multi-channel Merchant has a good article covering the issues.

My personal opinion is that the USPS needs the flexibility to renegotiate labor contracts. These “fixed costs,” which should not be fixed, are the underlying factor dragging down the basic supply and demand economics of our postal system. So – do you think that all of the postal workers should keep their jobs even if there is no work to do? Do you believe that a postal rate hike will cost jobs in other sectors? Do you think that reducing the amount of mail will have environmental benefits that will outweigh the economic impact? If you feel strongly about any of these issues – I’d like to hear about it (and you should tell your representatives in the Congress and Senate too!)

Fighting the Good Fight: Say “No” to Postal Rate Increase

Monday, July 26th, 2010

By now you’ve heard all about the pending rate increase.  If the Postal Regulatory Commission allows this rate case to happen (which by the way is over 10 times the amount allowed by law), I predict you will see a major slide in mail volume and a major slide in the economy. To date, I don’t believe that Congress has made this connection.

mailboxIf you go to the Affordable Mail Alliance website, you’ll see a list of those supporting an end to this madness.  Take a look at the “Value Chain” and understand how your business–and even your town–will be affected.  Paper manufacturers, printers, ad agencies, mailing companies, high tech, and the list goes on will all suffer from the lack of mail. The USPS should be improving its business model and reducing costs, not increasing rates that will ultimately cause a decrease in mail.

Senator Susan Collins of Maine has spoken out and gone on record that this rate hike is not within the guidelines governing the USPS. Her formal statement can be found here.

Call the Postal Regulatory Commission: tell them to reject unfair rate hikes: 202-789-6800.

Opportunities in HR and Health Communications

Monday, June 21st, 2010

There was an article in Employee Benefit News last week talking about the challenges that employers and health plans face in trying to communicate the impact of healthcare reform. There is massive confusion among employees about how changes will affect them, and health plans have not reacted effectively to combat this confusion.

Some healthcare organizations have stepped up to the challenge. According to Shawn Connors, president of Hope Health, You need to accept that, whether you like it or not, you’re somewhat in the publishing business. “ Health plans should be stepping up to the plate with a menu of communications to support employers with explaining coverage, the impact of health reform on coverage and to develop and manage wellness plans that save both the employer and plans money. The EBN article cites some compelling statistics from JD Power on current satisfaction with health plans which underscore the importance of communications.

When health plans don’t provide adequate communications, employers are left to fill in the gaps and are often poorly equipped to do so. In many cases, the employers themselves don’t have a full grasp of all the nuances of their health plan (or plans) and most (like the rest of us) don’t have a clear understanding of how healthcare reform will impact their specific company benefits.

This presents an opportunity for professional communicators to step in and provide solution templates along with consulting support to help health plans and individual employers deliver the necessary series of communications to employees. Succeeding in this market will require developing expertise in the HR and healthcare market, or partnering with someone who is already operating in that space. Several experts are referenced in the article “Fight confusion with communication” and others are referenced on the EBN site.

A highly regulated market going through change where communications provide an opportunity to boost satisfaction and save money seems like a good avenue for business starved printers to pursue. Healthy hunting!