TITLE 44

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP12-00036R000100020021-6
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 18
• Document Creation Date: December 23, 2016
• Document Release Date: August 26, 2013
• Sequence Number: 21
• Publication Date: February 28, 1978
• Content Type: MEMO

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28 FEB 1978
MEMORANDUM FOR: Director of Logistics
FROM:
Chief, Printing and Photography Division, OL
SUBJECT: Title 44
1. Per instructions we have drafted a memo (att 1) for the
DDA to send to the DCI to back up another draft (att 2) of a
letter from the DCI to Senator Cannon, Chairman, Joint Committee
on Printing (JCP), both pertaining to Title 44. Also attached
(att 3) is a wild alternative in the form of a proposed draft
from the Agency's Legislative Counsel to the Staff Director of -
the JCP. Also pertinent to this question of Title 44 is my
memo (att 4) to.OL/PUS of 24 Feb re S.2525.
2. We have gone through several iterations of the basic
draft correspondence and are not confident that either the
substance or procedural plans are correct. . The rationale for
requesting waivers to specific provisions of the Government
Printing and Binding Regulations is, in my mind, somewhat spurious
In truth, PPD could live with compliance with all provisions,
notwithstanding the added administrative burden. The basic
problem lies with Agency publishers, particularly NFAC, and their
difficulties with delays and restrictions that could be imposed,
e.g. compliance with the GPO Style Manual.
3. Sec 8 of Public Law 110 exempted. us, S.2525 exempts us,
the staff of the JCP and GPO exempts us, at least tacitly. Why
do we not want to be exempt?
STAT
TAT
OL 8 0853
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MEMORANDUM FOR:. Director of Central Intelligente.
VIA: Deputy Director of Central Intelligence
FROM: John F. Blake
Deputy Director for Administration
SUBJECT: Title 44, United States Code,
Public Printing and Documents
? 1. Action Requested: It is requested that selected
exemptions from the Government Printing and Binding Regulations
be sought from the Joint 'Committee on Printing (JCP) on behalf
of all Agency printing componenis.
2. Background:
a. The Central Intelligence Agency (CIA), through
numerous contacts over the years between the Printing
and Photography Division (PPD) and the Government
Printing Office (GPO) and JCP, has been under the
impression that Agency printing activities were exempt
from Title 44, U.S.C. It was felt that at least tacit'
approval, in some instances specific waivers, covered
any activities that might be construed as noncompliance
with the code. In the course of recent reviews, including
that prompted by your interest in making as many publica-
tions of the Agency available to the public as possible
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through the Federal Depository Library Program (FDLP),
the Office of General Counsel has determined that the
Agency has never had a formal exemption from the code.
Certainly, there was never any attempt to deliberately
defy any provisions of Title 44. There has been a
close relationship between our PUD and the GPO. The
Public Printer and his staff have been kept informed of
our equipment, methods and products and have never
raised any objections or voiced any concern over CIA
printing activities. Both organizations have common
wage systems and managerial structures and PUD recognizes
GPO as the facility authorized to perform most federal
printing and as the procurer of printing papers.
b. The close relationship of the two organizations
has allowed the free exchange of information and ideas,
sometimes acqui.red through research and development.
The end result of this liaison has been the selection
of similar equipment in the two facilities. This
compatibility of systems has insured both organizations
of having a pool of parts inventories that can be shared
on an emergency basis.
c. PUD relies extensively on GPO for its supply
of paper stocks. Other dhannels for the acquisition of
supplies are utilized by PUD only on occasions when
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special stocks not inventoried by GPO are required. In
past years, waivers had been obtained from the Public
Printer allowing the purchase of these special stocks
and for the procurement of printing from commercial
vendors, as necessary.
d. The FDLP of GPO is supported by PUD on a daily
basis. By utilizing this channel, unclassified Agency
publications are made available to the general public.
Beyond this channel, PUD and GPO have established a
cost effective program which allows unclassified documents
printed by PUD deemed to be of interest to the general
public to be sold by the Superintendent of Documents,
GPO at only the production cost.
3. Staff Position:
a. The obvious interest of PUD is to continue to
comply with the Government Printing and Binding Regulations
except in those instances of unique requirements arising
from security or the needs of our users. In the past,
this compliance has most often been identified by the
close liaison of PUD with GPO in regard to equipment
and materiel acquisitions and through waivers obtained
from the Public Printer for specialty items.
b. In the interest of operational efficiency and
cost effectiveness PUD should be allowed to continue
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STAT
to operate under the same general guidelines that it
has utilized successfully through the years. Sections
103 and 501 of Title 44 provide the basis for exemptions
from the Government Printing and Binding Regulations that
can be granted by the JCP. In this regard specific
exemptions from the JCP to allow PUD to acquire equipment,
materiel, and commercial procurement of printing without
the JCP approval would satisfy the need for the required
PUD flexibility in its operations. Other stipulations
contained in the Government Printing and Binding Regulations
would be strictly adhered to.
4. Recommendation: It is recommended that the JCP be
requested to grant the Agency exemptions from paragraphs 9 through
12, 34, 46, and all reporting requirements (see attachment) as
stated in the Government Printing and Binding Regulations.
Att.
Distribution:
Orig - Addressee
1 - DDCI
1 - ER
2 - DDA
1 - OL Official
Originating Office
John F. Blake
James H. McDonald Date
Director of Logistics
Distribution Withheld:
1 - DL Chrono
1 - OL/PUD
OL/PUD
(23 February 1978)
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Government Printing and Binding Regulations
Title II - EQUIPMENT
Paragraph 9 (Stipulation): The regulation specifies
that the JCP must approve the purchase, rental, or transfer
of equipment. Also, that the request submitted to the JCP
for equipment approval must contain a statement citing
the need for the proposed equipment as well as the identi-
fication of the installation where the equipment is to be
located.
Rationale for Exemption: The mission of the CIA printing
facilities is toproduce classified documents which contain
perishable data in a timely manner without a sacrifice in
quality. Therefore, the equipment used to satisfy these
requirements of timeliness and quality must be evaluated by
Agency officials who are knowledgeable of the documents that
are produced. Equipment transactions are under strict budgetary
controls and all Federal Government and procurement regulations
are adhered to.
Paragraph 10 (Stipulation): The regulation specifies
that disposals of equipment be conducted in accordance
with existing procedures without prior reference to the
JCP, except that disposals must be reported to the JCP
within 30 days.
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Rationale for Exetption Agency printing facilities
dispose of equipment in accordance with Agency regulations.
A waiver from the JCP reporting requirement is requested
in order to eliminate duplicate reporting, and for the
reasons cited above.
Paragraph ' 11 ' .(Stipulation): Paragraph 11 requires
the approval of the JCP prior to the acquisition of new
processes which would replace traditional processes. Para-
graph 12 requires the reporting to the JCP.of intent to engage
in applied research which may affect the printing, binding,
or related fields.
Rationale for Exemption: An important objective of
the Agency is to disseminate intelligence information of
a perishable nature within very short time constraints.
Consequently, Agency printing components constantly seek.
improvements in equipment or processes that may push
the current state of the art. A waiver would allow this
development to continue uninhibited since its effect on
traditional methods is never given consideration.
Title III.- General Provisions
Paragraph 34 .(Stipulation): This paragraph requires
Government printing facilities to abide.by JCP specifications
and standards in regard to paper stocks. It also offers the
opinion of the JCP that semiannual and annual paper contracts
are not in the best interest of Government and that such
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contracts should be used only when savings in costs are
clearly demonstrable.
Rationale for Exemption: Paper used in Agency printing
facilities must be of sufficient quality to insure the
excellence of photographic detail in the printed product.
In order to avoid the excessive,variation of ink colors
and photographic detail, the Agency acquires stocks via
contracts with commercial vendors on a price bid basis.
Tolerances allowed in the written specifications of these
stocks are more stringent than those for ordinary Government
printing. However, CIA purchases this better grade paper
commercially at less cost than it could obtain a lower grade
paper through normal Government channels. Savings in paper
costs are clearly demonstrable.
Paragraph 46 (StipUlation): The regulation delegates
authority to the Public Printer for issuance of a waiver
for Government departments to make direct purchases of
printing, binding, or related material.
Rationale for Exemption: The Agency frequently relies
on commercial vendors for the printing of specialized forms
and for providing unique binding that neither CIA nor the
U.S. Government 'Printing Office is equipped to perform. On
these occasions the products can be obtained more quickly
and at less cost via direct transactions between the Agency
and the vendor. Title 44, U.S.C., Section 103 allows the
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JCP to use any measures necessary to avoid "duplication, delay,
or waste". Direct purchases, in selected cases, avoid duplica-
tion and delay.
Title IV - Joint Committee on Printing Report Forms
Paragraph 48: Production Report
Paragraph 49: Commercial Printing Report
Paragraph 50: Power Collator Acquisitions Report
Paragraph 51: Map & Chart Production Report
Paragraph 52: Plant Inventory Report
Paragraph 53: Stored Equipment Report
Paragraph 54: Excess Equipment Report
Rationale for Exemption: CIA printing facilities report
to Agency management production, commercial printing procurements
and the status of various equipment and inventories. As noted
previously, the very unique and sensitive nature of the Agency's
printing does not lend itself to the required reporting.
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4.1-4-cJi\mc4
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The Director
Central Intelligence Agency
Washington, D. C.20505
The Honorable Howard W. Cannon, Chairman
Joint Committee on Printing
c/o U.S. Senate P.O.
Washington, D.C. 20510
Dear Senator Cannon,
Since the formal incorporation of Central Intelligence
Agency (CIA) printing facilities in 1957, the Agency has
operated under the specific instructions set down in the
printing facilities' implementing documents as well as under
the general guidelines of the Government Printing and Binding
Regulations of the Joint Committee on Printing (JCP). Where
strict adherence to the Government Printing and Binding Regula-
tions would impinge on sources or methods or seriously detract
from the flexibility required in fulfilling our mission, we
felt that we had at least tacit approval and in some instances
specific waivers from the JCP and the Government Printing Office
(GPO) to operate as we have.
Our close association with the JCP and with officials of
the GPO has been evident throughout our existence and is a
matter of formal record. Our relationship with GPO has its
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roots in a managerial structure and a wage system that is
common with the GPO and we recognize that organization as
the responsible department for most federal printing and as
the procurer of printing paper stocks. In this regard, we
rely on GPO as the primary source for our paper supply,
utilizing other channels only for specialty items not available
through GPO.
Our close liaison with GPO concomitant with the flexibility
of our internal operations has yielded many cost effective
programs. Utilizing the results of their research and develop-
ment programs, we have acquired similar equipment systems which
have insured a compatibility of language, training, and mutually
shared solutions to equipment and system problems. We have also
implemented an effective system for providing unclassified
documents printed by the CIA to be made available to the public
through the Superintendent of Documents, GPO. This program
supplements our compliance with the Federal Depository Library
Program which we contribute to on a daily basis.
Our Office of Legislative Counsel, working with the staff
of your JCP, has not been successful in finding any formal,
documented evidence of Agency exemption from any provision
of Title 44, United States Code. In the interest of maintaining
the flexibility and -efficiency that we have enjoyed over the
years, and in view of the sensitive nature of sources, methods
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and Products of our printing plant, exemptions from paragraphs
9 through 12, 34, 46, and all reporting requirementSin paragraphs
48 through 54 of the Government Printing and Binding Regulations
are requested.
Yours,
STANSFIEMD TURNER
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Mr. Denver Dickerson,
Staff Director, Joint Committee on Printing
United States Senate Post Office
Washington, D.C. 20510
Dear Denver,
As you know we have been wrestling with the question of
the Agency's exemption from the provisions of Title 44. We
all agree that over the years we have had tacit approval, if
not a formal written agreement, that CIA would, because of
special requirements and the sensitivity of its product, operate
with minor deviations from the Government Printing and Binding
Regulations.
Unless you foresee any objections on the part of the Joint
Committee on Printing we will continue to operate in this fashion.
Of course, we will continue with the very close liaison with the
Government Printing Office on matters of common interest and
concern. We would be most happy to furnish you and your staff
with any information concerning our printing activities that you
might find useful or necessary.
Sincerely,
Lyle L. Miller
Acting Legislative Counsel
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Declassified
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4 FEB 1978
MEMORANDUM FOR: Chief, Plans and Programs Staff, OL
FROM:
1)i Chief, Printing Photography Division, OL
SUBJECT: Comments ,in Proposed S.2525
STAT
.1. The wording in S.2525 pertaining to printing
and binding is almost identical to that in Sec.8. of PL 110.
I don't see anything in S.2525 resembling the preface to Sec.8,
viz, "notwithstanding any other provisions of law...", nor do I
know the impact of it's presence or absence. ,All pertinent
references in S.2525 to activities of concern to this division
are in Sec. 422.(a) (lines 23, 24, 25 on page 192 and lines
4,5 on page 193).
,I. The basis upon which this division has operated printing
and binding facilities are tied to A number of things specified
in my memo to the D/L of 1 Nov 1977 regarding Title 44 USC.
We read Set. 8'as total exemption from Title 44. Then there were
other agreements and precedence upon which we have been operating.
Of course, OGC, as outlined in their memo to D/L of 11 January 1978,
renders the opinion that "the Agency does not have blanket exemption
from the provisions of Title 44." We are busy now drafting corre-
spondence to the Joint Committee on Printing for waivers from .
specific provisions of Title 44.
3. 'What is the intent of Sec. 422 in S.2525? In my mind,
I interpret it just the same as Sec.8, but then OGC doesn't
agree. If we are subject to Title 44, why is it in Sec. 422?
The whole point of S.2525 is to tell us what and what not to.
do. We end up not with answers but questions.
ILLEGIB
STAT
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