B-142360, JUN. 3, 1960

B-142360: Jun 3, 1960

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IN WHICH A SIMILAR QUESTION WAS RAISED BY THE GENERAL SERVICES ADMINISTRATION. THE FREIGHT CHARGES FOR THESE SHIPMENTS ARE REPORTEDLY NOMINAL IN AMOUNT AND THE BUREAU OF PRISONS FEELS THAT THE USE OF IMPREST FUNDS FOR THE PAYMENT OF SUCH CHARGES AND THE ELIMINATION OF THE REQUIREMENT FOR THE ISSUANCE OF GOVERNMENT BILLS OF LADING TO COVER EACH SHIPMENT WOULD RESULT IN CONSIDERABLE SAVINGS. WE HAVE GIVEN CAREFUL CONSIDERATION TO TWO FEATURES OF THE INSTANT PROPOSAL AND HAVE CONCLUDED THAT THEY ARE ESSENTIALLY NO DIFFERENT FROM SEVERAL OF THE SUGGESTIONS CONSIDERED AND DISCUSSED IN 38 COMP. WERE MADE THE SUBJECT OF THOROUGH STUDY BY OUR STAFF AND FOR REASONS SUMMARIZED THEREIN MAY NOT PROPERLY BE APPROVED.

B-142360, JUN. 3, 1960

TO THE SECRETARY OF THE TREASURY:

BY LETTER DATED MARCH 21, 1960, WITH ENCLOSURES, THE FISCAL ASSISTANT SECRETARY REQUESTS, IN VIEW OF OUR DECISION OF JANUARY 6, 1959 (B-135157), 38 COMP. GEN. 462, IN WHICH A SIMILAR QUESTION WAS RAISED BY THE GENERAL SERVICES ADMINISTRATION, THAT WE CONSENT ON A PROCEDURE FOR THE USE OF IMPREST PETTY CASH FUNDS PROPOSED BY THE BUREAU OF PRISONS OF THE DEPARTMENT OF JUSTICE. THE PROPOSAL CONTEMPLATES THE DISCONTINUANCE OF THE ISSUANCE OF GOVERNMENT BILLS OF LADING AND THE USE OF IMPREST PETTY CASH FUNDS TO PAY RECURRING FREIGHT CHARGES FOR SHIPMENTS OF FRESH MILK BETWEEN CERTAIN FEDERAL CORRECTIONAL INSTITUTIONS AND OF MILK SAMPLES FORWARDED BY SUCH INSTITUTIONS TO STATE HEALTH AGENCIES FOR BACTERIA COUNT. THE FREIGHT CHARGES FOR THESE SHIPMENTS ARE REPORTEDLY NOMINAL IN AMOUNT AND THE BUREAU OF PRISONS FEELS THAT THE USE OF IMPREST FUNDS FOR THE PAYMENT OF SUCH CHARGES AND THE ELIMINATION OF THE REQUIREMENT FOR THE ISSUANCE OF GOVERNMENT BILLS OF LADING TO COVER EACH SHIPMENT WOULD RESULT IN CONSIDERABLE SAVINGS.

WE HAVE GIVEN CAREFUL CONSIDERATION TO TWO FEATURES OF THE INSTANT PROPOSAL AND HAVE CONCLUDED THAT THEY ARE ESSENTIALLY NO DIFFERENT FROM SEVERAL OF THE SUGGESTIONS CONSIDERED AND DISCUSSED IN 38 COMP. GEN. 462, NAMELY SUGGESTIONS NOS. 1 AND 2 PRESENTED BY THE GENERAL SERVICES ADMINISTRATION. THE REASONS STATED THEREIN FOR DISAPPROVING SUCH SUGGESTIONS APPEAR EQUALLY APPLICABLE TO THE SHIPMENTS OF MILK MADE BY THE BUREAU OF PRISONS BETWEEN INSTITUTIONS AND OF MILK SAMPLES FORWARDED TO THE STATE HEALTH AGENCIES FOR BACTERIA COUNT. AS POINTED OUT IN OUR DECISION TO THE ADMINISTRATOR OF GENERAL SERVICES, SUGGESTIONS AND PROPOSALS, SIMILAR TO THOSE PRESENTED HERE, WERE MADE THE SUBJECT OF THOROUGH STUDY BY OUR STAFF AND FOR REASONS SUMMARIZED THEREIN MAY NOT PROPERLY BE APPROVED. THE BUREAU OF PRISONS SEEMS TO HAVE OVERLOOKED THE FACT THAT, IN ANY EVENT, SOME SORT OF A SHIPPING DOCUMENT, WHETHER A GOVERNMENT BILL OF LADING OR A COMMERCIAL BILL WILL HAVE TO BE PREPARED AND WE CAN PERCEIVE NO GREAT DIFFERENCE IN THE BURDEN OF PREPARING THE TWO TYPES OF DOCUMENTATION.

WE NOTE THAT ONE OF THE ENCLOSURES TO MR. HEFFELFINGER'S LETTER INDICATES THAT UNDER CURRENT PROCEDURES, THE CHARGES FOR SHIPMENTS OF MILK PREPAID. PREPAYMENT OF TRANSPORTATION CHARGES APPEAR TO BE PROHIBITED BY PREPAID. PREPAYMENT OF TRANSPORTATION CHARGES APPEAR TO BE PROHIBITED BY R.S. 3648, 31 U.S.C. 529. SEE 30 COMP. GEN. 348 APPLYING THE FOREGOING STATUTE TO TRANSPORTATION CHARGES. SUCH ADVANCED PAYMENTS SHOULD BE ELIMINATED AND IT IS SUGGESTED THAT A DISCUSSION OF THE PROBLEMS INHERENT IN THE RECURRING SHIPMENTS INVOLVED BETWEEN REPRESENTATIVES OF THE BUREAU OF PRISONS AND MEMBERS OF OUR TRANSPORTATION DIVISION MIGHT BE PRODUCTIVE IN THE ESTABLISHMENT OF PROPER AND ECONOMICAL PROCEDURES FOR THE TRANSPORTATION OF SUCH SHIPMENTS.

THE LETTERS OF OCTOBER 22, AND NOVEMBER 25, 1959, ENCLOSED WITH MR. HEFFELFINGER'S LETTER, ARE RETURNED.