B-126454, FEB. 23, 1956

B-126454: Feb 23, 1956

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VETERANS ADMINISTRATION: REFERENCE IS MADE TO YOUR LETTER OF DECEMBER 22. IT IS STATED IN THE ABOVE-MENTIONED LETTER THAT THE VETERANS ADMINISTRATION PURCHASES APPROXIMATELY 350. IT IS FURTHER STATED THEREIN THAT THE ISSUANCE OF THIS LARGE NUMBER OF GOVERNMENT BILLS OF LADING TO CONTRACTORS IN ADVANCE REQUIRES THE MAINTENANCE OF RECORDS. THE LETTER ALSO STATES THAT CONSIDERABLE ADMINISTRATIVE SAVINGS COULD BE MADE IF PERMISSION WERE GRANTED THE VETERANS ADMINISTRATION TO HAVE THESE SHIPMENTS MADE ON COMMERCIAL BILLS OF LADING TO BE CONVERTED TO GOVERNMENT BILLS OF LADING AT DESTINATION. IT IS UNDERSTOOD HERE THAT COAL SHIPMENTS GENERALLY ORIGINATE AT MINES AT WHICH NEITHER THE CARRIER NOR THE GOVERNMENT HAS ANY AGENT.

B-126454, FEB. 23, 1956

TO HONORABLE H. V. HIGLEY, ADMINISTRATOR, VETERANS ADMINISTRATION:

REFERENCE IS MADE TO YOUR LETTER OF DECEMBER 22, 1955, REQUESTING AUTHORITY TO SHIP COAL PROCURED TO COVER YOUR ADMINISTRATION'S ANNUAL REQUIREMENTS ON COMMERCIAL BILLS OF LADING TO BE CONVERTED AT DESTINATION TO GOVERNMENT BILLS OF LADING.

IT IS STATED IN THE ABOVE-MENTIONED LETTER THAT THE VETERANS ADMINISTRATION PURCHASES APPROXIMATELY 350,000 TONS OF COAL ANNUALLY ON CONTRACT F.O.B. CARS AT THE MINES WHICH, UNDER EXISTING PROCEDURE, REQUIRES THE ISSUANCE OF APPROXIMATELY 7,000 GOVERNMENT BILLS OF LADING ANNUALLY BY VETERANS ADMINISTRATION FIELD STATIONS. IT IS FURTHER STATED THEREIN THAT THE ISSUANCE OF THIS LARGE NUMBER OF GOVERNMENT BILLS OF LADING TO CONTRACTORS IN ADVANCE REQUIRES THE MAINTENANCE OF RECORDS, SUCH CORRESPONDENCE PERTAINING TO LOST OR MISLAID GOVERNMENT BILLS OF LADING, REQUESTS FOR ADDITIONAL BILLS OF LADING, AND SPECIAL REQUESTS FOR RELIEF FROM GENERAL ACCOUNTING OFFICE GENERAL REGULATION NO. 97 PERMITTING EMERGENCY SHIPMENT ON COMMERCIAL BILLS OF LADING TO BE CONVERTED TO GOVERNMENT BILLS OF LADING AT DESTINATION. THE LETTER ALSO STATES THAT CONSIDERABLE ADMINISTRATIVE SAVINGS COULD BE MADE IF PERMISSION WERE GRANTED THE VETERANS ADMINISTRATION TO HAVE THESE SHIPMENTS MADE ON COMMERCIAL BILLS OF LADING TO BE CONVERTED TO GOVERNMENT BILLS OF LADING AT DESTINATION.

IT IS UNDERSTOOD HERE THAT COAL SHIPMENTS GENERALLY ORIGINATE AT MINES AT WHICH NEITHER THE CARRIER NOR THE GOVERNMENT HAS ANY AGENT. THE CARS LOADED WITH COAL MOVE FROM THE MINE ON MINE CARDS THAT ARE LIFTED BY THE CONDUCTOR OF THE FREIGHT TRAIN WHICH PICKS UP THE CARS AND TRANSPORTS THEM TO THE DESTINATIONS NAMED ON THE CARDS. THE MINE CARDS ARE TURNED IN AT THE FIRST AGENCY STATION WHICH THE TRAIN PASSES AND IT IS AT THAT POINT THAT THE BILLS OF LADING ARE ISSUED, TOGETHER WITH SUCH OTHER DOCUMENTS AS ARE NECESSARY FOR THE CONVENIENCE OF THE RAILROAD IN THE MOVEMENT OF THE CARS TO THEIR DESTINATIONS. IN VIEW OF THIS METHOD OF HANDLING COAL SHIPMENTS, IT READILY CAN BE APPRECIATED THAT THE ISSUING AND POLICING OF THE LARGE NUMBER OF GOVERNMENT BILLS OF LADING REQUIRED FOR THE SHIPMENT OF THE VETERANS ADMINISTRATION'S ANNUAL COAL REQUIREMENTS CAN PRESENT A SERIOUS PROBLEM TO YOUR AGENCY.

IN THE CIRCUMSTANCES, WE WILL NOT OBJECT TO YOUR ADMINISTRATION AUTHORIZING THE USE OF COMMERCIAL BILLS OF LADING TO COVER THE SHIPMENT OF COAL PROCURED TO COVER ITS ANNUAL REQUIREMENTS, PROVIDED THAT EACH SUCH COMMERCIAL BILL OF LADING BEARS INDORSEMENTS TO THE EFFECT THAT THE SHIPMENT COVERED THEREBY IS "GOVERNMENT PROPERTY," THAT THE BILL OF LADING IS "TO BE CONVERTED AT DESTINATION TO U.S. GOVERNMENT BILL OF LADING" IN ACCORDANCE WITH THE PROVISIONS OF GENERAL REGULATION NO. 97-REVISED, AND THAT SUCH BILL OF LADING IS "SUBJECT TO ALL THE TERMS AND CONDITIONS OF THE GOVERNMENT BILL OF LADING.'