B-5638, SEPTEMBER 16, 1939, 19 COMP. GEN. 374

B-5638: Sep 16, 1939

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1939: I HAVE YOUR LETTER OF AUGUST 16. AS FOLLOWS: THE DISTRICT ENGINEER OFFICES UNDER THE CORPS OF ENGINEERS ARE EXPERIENCING CONSIDERABLE DIFFICULTY IN DETERMINING WHEN REPRODUCTION WORK PRODUCED BY LITHOGRAPH. NUMEROUS EXCEPTIONS HAVE BEEN TAKEN BY THE GENERAL ACCOUNTING OFFICE TO THE VOUCHERS ON WHICH PAYMENTS WERE MADE FOR THIS CLASS OF WORK BECAUSE A FIELD PRINTING CERTIFICATE WAS NOT ATTACHED. GEN. 111 AND 549) HAVE BEEN INTERPRETED AS REQUIRING THAT ALL WORK PRODUCED BY THE ABOVE- STATED PROCESSES SHOULD BE CLASSED AS FIELD PRINTING IF THE SUBJECT MATTER CONTAINED ANY LETTERING THAT COULD BE PRODUCED BY PRINTERS' TYPE. THE DISTRICT ENGINEERS WERE INSTRUCTED BY THE CHIEF OF ENGINEERS TO CLASSIFY ALL SUCH REPRODUCTION WORK AS CONTRACT FIELD PRINTING.

B-5638, SEPTEMBER 16, 1939, 19 COMP. GEN. 374

PRINTING AND BINDING - PRINTING - DUPLICATIONS FOR CURRENT NEEDS - STATUS UNDER DEFINITION OF PRINTING THE PRODUCTION OF DUPLICATIONS, BY PHOTOLITHOGRAPHIC OR SIMILAR PROCESSES, OF HAND DRAWINGS SHOWING CONSTRUCTION DETAILS OF A DAM, WITH NO BINDING, SEWING OR TRIMMING OPERATION, FOR USE IN THE CURRENT OPERATIONS OF THE CORPS OF ENGINEERS, INVOLVES DUPLICATING RATHER THAN PRINTING AND BINDING, AND THE COPIES SO PRODUCED DO NOT COME WITHIN THE DEFINITION OF PRINTING AS APPARENTLY ADOPTED BY THE JOINT COMMITTEE ON PRINTING. COMP. GEN. 111; ID. 549, AMPLIFIED.

COMPTROLLER GENERAL BROWN TO THE SECRETARY OF WAR, SEPTEMBER 16, 1939:

I HAVE YOUR LETTER OF AUGUST 16, 1939, AS FOLLOWS:

THE DISTRICT ENGINEER OFFICES UNDER THE CORPS OF ENGINEERS ARE EXPERIENCING CONSIDERABLE DIFFICULTY IN DETERMINING WHEN REPRODUCTION WORK PRODUCED BY LITHOGRAPH, PHOTOLITHOGRAPH, MULTIGRAPH, PLANOGRAPH, AND SIMILAR PROCESSES SHOULD COME WITHIN THE CATEGORY OF CONTRACT FIELD PRINTING, AND WHEN SUCH WORK COULD BE CLASSED AS "PERMISSIBLE DUPLICATING" WITHOUT BEING CHARGED TO THE CONTRACT FIELD PRINTING AUTHORIZATIONS OR REQUIRING THE CERTIFICATE PRESCRIBED BY TITLE II, PARAGRAPH 101 OF THE REGULATIONS OF THE JOINT COMMITTEE ON PRINTING TO BE PLACED ON THE VOUCHER. NUMEROUS EXCEPTIONS HAVE BEEN TAKEN BY THE GENERAL ACCOUNTING OFFICE TO THE VOUCHERS ON WHICH PAYMENTS WERE MADE FOR THIS CLASS OF WORK BECAUSE A FIELD PRINTING CERTIFICATE WAS NOT ATTACHED.

DECISIONS OF THE ACTING COMPTROLLER GENERAL (16 COMP. GEN. 111 AND 549) HAVE BEEN INTERPRETED AS REQUIRING THAT ALL WORK PRODUCED BY THE ABOVE- STATED PROCESSES SHOULD BE CLASSED AS FIELD PRINTING IF THE SUBJECT MATTER CONTAINED ANY LETTERING THAT COULD BE PRODUCED BY PRINTERS' TYPE, REGARDLESS OF WHETHER IT WOULD BE PRACTICABLE TO BE DONE BY PRINTERS' TYPE. IN CONFORMITY WITH THIS INTERPRETATION, THE DISTRICT ENGINEERS WERE INSTRUCTED BY THE CHIEF OF ENGINEERS TO CLASSIFY ALL SUCH REPRODUCTION WORK AS CONTRACT FIELD PRINTING, AND TO FURNISH THE REQUIRED CERTIFICATE ON THE VOUCHER IF THE SUBJECT MATTER REPRODUCED CONTAINED ANY STRAIGHT- LINE LETTERING THAT WAS CAPABLE OF BEING PRODUCED BY PRINTERS' TYPE.

IN A PAMPHLET ENTITLED " PRODUCTION AND DISTRIBUTION OF PRINTED AND PROCESSED MATTER FOR THE EXECUTIVE DEPARTMENTS" PRINTED IN THE UNITED STATES GOVERNMENT PRINTING OFFICE IN 1938 FOR USE OF THE JOINT COMMITTEE ON PRINTING, THERE APPEARS THE OPINION OF THE ACTING COMPTROLLER GENERAL OF THE UNITED STATES DATED JUNE 1, 1938. IN THIS OPINION HE STATES HE HAS NO OBJECTION TO THE ADOPTION OF THE DEFINITION OF THE WORD "PRINTING" APPARENTLY PROPOSED TO BE ADOPTED BY THE JOINT COMMITTEE ON PRINTING IN A LETTER DATED APRIL 29, 1938, ADDRESSED TO THE ACTING DIRECTOR, BUREAU OF THE BUDGET. IN THE LETTER OF APRIL 29 THE COMMITTEE IS OF THE OPINION THAT THE TERM "PRINTING" "SHALL NOT INCLUDE MATTER REPRODUCED BY WHAT IS COMMONLY KNOWN AS THE MIMEOGRAPH OR STENCIL PROCESS, NOR SHALL IT INCLUDE REPRODUCTIONS BY OTHER DUPLICATING PROCESSES IF CONFINED STRICTLY TO MATTER REQUIRED CURRENTLY IN THE PERFORMANCE OF FUNCTIONS AUTHORIZED BY LAW * * * AND IF NO BINDING, SEWING, OR TRIMMING OPERATION IS INVOLVED IN CONNECTION THEREWITH.'

THERE ARE ENCLOSED HEREWITH SAMPLES OF FIVE JOBS THAT WERE REPRODUCED BY THE PHOTOLITHOGRAPH METHOD. IN VIEW OF THE DEFINITION OF THE TERM "PRINTING" STATED IN THE PAMPHLET REFERRED TO IN PARAGRAPH 3, IT IS APPARENT THESE FIVE REPRODUCTIONS SHOULD NOT BE CLASSIFIED AS PRINTING, AND THEIR PURCHASE IN THE FIELD, WITHOUT SUBMISSION TO THE GOVERNMENT PRINTING OFFICE AND RELEASE SIGNED BY THE PUBLIC PRINTER THAT HE WAS NOT IN A POSITION TO DO THE WORK WAS AUTHORIZED, AND THAT CERTIFICATE TO THE EFFECT THAT THE WORK WAS URGENT OR NECESSARY TO HAVE DONE ELSEWHERE THAN IN THE DISTRICT OF COLUMBIA FOR THE EXCLUSIVE USE OF A FIELD OFFICE IS NOT NECESSARY.

IN VIEW OF THE GENERAL ACCOUNTING OFFICE EXCEPTIONS AND TO CLARIFY THE SITUATION AS IT NOW EXISTS, A DECISION IS REQUESTED THAT WILL ESTABLISH A DEFINITE PROCEDURE FOR CLASSIFICATION OF REPRODUCTION WORK SUCH AS REFERRED TO IN THE FIRST PARAGRAPH.

WITH RESPECT TO THE USE OF PRINTERS' TYPE IN DUPLICATING WORK IT WAS STATED IN THE DECISION IN 16 COMP. GEN. 549, PAGE 550, AS FOLLOWS:

* * * IT MAY BE, AS YOU INDICATE, THAT THE USE OF REGULAR PRINTING TYPE FOR HEADINGS, ETC., ON SUCH DUPLICATING WORK WILL MAKE MORE EFFECTIVE COPY, BUT IF THE USE OF REGULAR PRINTING TYPE IS NECESSARY FOR THIS PURPOSE, THE WORK ITSELF TENDS TO LOSE ITS CHARACTER OF PERMISSIBLE DUPLICATING AND MAY BE REGARDED AS PRINTING. * * * THUS WHILE THAT DECISION AND THE PRECEDING DECISION IN 16 COMP. GEN. 111, NEGATIVED THE PURCHASE OF PRINTERS' TYPE FOR USE IN DUPLICATING MACHINES, THEY DID NOT HOLD THAT ANY MATTER WHICH MIGHT HAVE BEEN PRODUCED BY PRINTERS' TYPE BUT WHICH WAS NOT SO PRODUCED CONSTITUTED PRINTING. CONSEQUENTLY, THE QUESTION OF WHETHER THE COPY MIGHT POSSIBLY HAVE BEEN PRODUCED BY PRINTERS' TYPE CONSTITUTES NO PART OF THE DEFINITION OF PRINTING. STATED IN YOUR LETTER IT WAS SAID IN DECISION OF JUNE 1, 1938, A-90545, TO THE DIRECTOR OF THE BUDGET, THAT THIS OFFICE WOULD HAVE NO OBJECTION TO THE ADOPTION BY THE JOINT COMMITTEE ON PRINTING OF A DEFINITION OF PRINTING AS FOLLOWS:

* * * THE TERM "PRINTING" AS USED IN THE LAST PROVISION OF CHAPTER 86, SECTION 11 (40 STAT. 1270) OF THE LEGISLATIVE, EXECUTIVE, AND JUDICIAL APPROPRIATION ACT FOR THE FISCAL YEAR ENDING JUNE 30, 1920, APPROVED MARCH 1, 1919 ( U.S.C., TITLE 44, SEC. 111), INSOFAR AS IT RELATES TO PRINTING FOR THE EXECUTIVE DEPARTMENTS, INDEPENDENT OFFICES, OR ESTABLISHMENTS OF THE GOVERNMENT IN THE DISTRICT OF COLUMBIA, OR ELSEWHERE, SHALL INCLUDE PAMPHLETS, BOOKS, DOCUMENTS, PERIODICALS, AND OTHER PUBLICATIONS OF A PERMANENT CHARACTER, ALSO BLANK BOOKS AND STANDARDIZED FORMS, BUT SHALL NOT INCLUDE MATTER REPRODUCED BY WHAT IS COMMONLY KNOWN AS THE MIMEOGRAPH OR STENCIL PROCESS, NOR SHALL IT INCLUDE REPRODUCTIONS BY OTHER DUPLICATING PROCESSES IF CONFINED STRICTLY TO MATTER REQUIRED CURRENTLY IN THE PERFORMANCE OF FUNCTIONS AUTHORIZED BY LAW, SUCH AS RULES, REGULATIONS, INSTRUCTIONS, OPINIONS, DECISIONS, NOTICES, CIRCULARS, STATISTICAL STATEMENTS, AND OTHER INFORMATIONAL MATTER, AND IF NO BINDING, SEWING, OR TRIMMING OPERATION IS INVOLVED IN CONNECTION THEREWITH.

THE SAMPLES ACCOMPANYING YOUR SUBMISSION ARE DUPLICATIONS OF DRAWINGS GIVING CONSTRUCTION DETAILS OF THE OHIO RIVER MONTGOMERY ISLAND DAM. THE ORIGINALS APPARENTLY WERE DRAWN BY HAND, AND THE COPIES APPARENTLY PRODUCED BY PHOTOLITHOGRAPHIC OR SIMILAR PROCESSES FOR USE IN THE CURRENT OPERATIONS OF THE CORPS OF ENGINEERS. DUPLICATING RATHER THAN PRINTING IS INVOLVED IN SUCH PRODUCTION WITH NO BINDING, SEWING, OR TRIMMING OPERATION. IF SUCH ARE THE FACTS, THE COPIES PRODUCED DO NOT COME WITHIN THE DEFINITION OF PRINTING AS ABOVE QUOTED.

THE EXCEPTIONS REFERRED TO IN YOUR SUBMISSION WILL BE ADJUSTED ACCORDINGLY.