U.S. GOVERNMENT PRINTING OFFICE
   BOARD OF CONTRACT APPEALS
   WASHINGTON, DC  20401

In the Matter of                 )
                                 )
The Appeal of                    )
                                 )
MCDONALD & EUDY PRINTERS, INC.   )    Docket No. GPO BCA 25-92
Program C696-S                   )
Purchase Order 91372             )
Print Orders 40023, 40024        )
  and 40026                      )

   DECISION AND ORDER

   By letter dated July 22, 1992, McDonald & Eudy Printers, Inc.
   (Appellant or Contractor), 4509 Beech Road, Temple Hills,
   Maryland 20748, filed a timely appeal from the July 2, 1992,
   final decision of Contracting Officer Jack Scott, of the U.S.
   Government Printing Office's (Respondent or GPO or Government)
   Printing Procurement Department, Washington, DC 20401,
   rejecting the Appellant's request for an equitable adjustment
   of $2,127.80 for reprinting text signatures under its contract
   identified as Program C696-S, Purchase Order 91372, Print
   Orders 40023, 40024, and 40026, because the Government-
   furnished camera copy for six (6) pages was incorrect (R4
   File, Tab H).1  Instead, the Contracting Officer allowed the
   claim only in the total amount of $727.42 for the three print
   orders involved (R4 File, Tab H).  For the reasons which
   follow, the decision of the Contracting Officer is hereby
   AFFIRMED, and the appeal is DENIED.2

   FINDINGS OF FACT3

   1. On May 10, 1991, the Respondent solicited bids for a
   single-award "requirements" contract, covering the period from
   July 1, 1991 through June 30, 1992, to produce and distribute
   "Defense Language Proficiency Test Booklets (DLPTBs)" for the
   Department of the Army's Publications and Printing Command
   (Army) (R4 File, Tab A, p. 1).4

   2. Among other specifications, the Invitation for Bids (IFB)
   contained the following clauses and provisions:

      QUANTITY: Approximately 4,000 copies per order.
      Occasionally an order may be placed for more or less than
      4,000 copies.

      NUMBER OF PAGES: Approximately 12 to 52 pages per order.

   * * * * * * * * * *

      GOVERNMENT TO FURNISH: Camera copy consisting of line art
      for text, line illustrations, and reprint copy to be
      reproduced same size.

      Film negatives.

      A supply of blue labels and selection certificates for
      shipping Departmental Random copies.

      One reproduction proof (image size 7-7/8 x 6-1/8") for
      shipping container labels.

      Identification markings such as register marks, ring
      folios, rubber stamped jacket numbers, commercial
      identification marks of any kind, etc., expect GPO imprint,
      form number, and revision date, carried on copy or film,
      must not print on finished product.

   * * * * * * * * * *

      FILMS: The contractor must make all films not furnished by
      the Government.  Films may be opaqued on either the
      emulsion or non-emulsion side.  The films delivered to the
      Government must be the final films used for printing.  They
      must be suitable for making press plates for subsequent
      reprinting without any retouching, opaquing, surprinting or
      any other hand or camera work.

      The contractor must not print prior to receipt of any "OK
      to print."

      PRIOR TO PRODUCTION SAMPLES: The sample requirement for
      this contract is not less than 4 serially numbered printed
      construction samples.  Each sample shall be printed and
      constructed as specified and must be of the size, kind, and
      quality that the contract will furnish.

      Samples will be inspected and tested and must comply with
      the specifications as to construction, kind and quality of
      materials.

      Prior to the commencement of production of the contract
      quantity, the contractor shall submit samples numbered
      000001 and 000002 to [the Army's Alexandria, Virginia
      facility] and samples numbered 000003 and 000004 to [the
      Army's Monterey, California facility].

      Four samples will be tested for conformance to
      specifications. . . . The samples must be submitted in
      sufficient time to allow Government testing of the samples
      and production and shipment in accordance with the shipping
      schedule.

      The Government will approve, conditionally approve, or
      disapprove the samples within 10 workdays of the receipt
      thereof.  Approval or conditional approval shall not
      relieve the contractor from complying with the
      specifications and all other terms and conditions of the
      contract.  A conditional approval shall state any further
      action required by the contractor.  A notice of disapproval
      shall state the reasons therefor.

   * * * * * * * * * *

      Manufacture of the final product prior to approval of the
      sample submitted is at the contractor's risk.  Samples will
      not be returned to the contractor.  All costs, including
      the costs of all samples shall be included in the contract
      price for the production quantity.5

See, R4 File, Tab A, pp. 5-6.  [Emphasis added.]

   3. The Contractor submitted a low bid of $37,616.04 (R4 File,
   Tab B).  On June 17, 1991, the Respondent issued Purchase
   Order 91372 awarding the contract to the Appellant (R4 File,
   Tab C).

   4. On March 31, 1992, the Army issued Print Orders 40023,
   40024, and 40026 to the Appellant for the production of 4,000
   copies each of three separate DLPTBs relating to Persian
   language listening, reading and speaking comprehension,
   respectively (R4 File, Tab D).  Since the delivery date for
   the DLPTBs was May 11, 1992, the Print Orders also required
   the Appellant to furnish four (4) sets of advanced proofs to
   the Government by April 6, 1992, with April 20, 1992, being
   established as the date for the return of the proofs to the
   Contractor (R4 File, Tab D).  Furthermore, each Print Order
   contained the following statement, in capital letters and
   emphasized by four stars preceding the words:

      ****FINAL PRODUCTION IS CONTINGENT UPON   APPROVAL OF
      ADVANCE COPIES.

(R4 File, Tab D).

   5. The Appellant furnished the required proofs for the three
   DLPTBs on time.  However, when the Army reviewed them it
   discovered that "[d]ue to departmental error, incorrect camera
   copy [had been] furnished[.]," and six (6) pages overall
   needed correction- specifically, page 13 of the DLPTB for
   Persian listening comprehension (Print Order 40023), pages 10,
   12, 17, and 24 of the DLPTB for Persian reading comprehension
   (Print Order 40024), and page 17 of the DLPTB for Persian
   speaking comprehension (Print Order 40026) (R4 File, Tab E).6
   Consequently, the Army furnished corrected camera copy for
   these pages, and told the Contractor to send new advanced
   copies of the DLPTBs to its Alexandria, Virginia and Monterey,
   California facilities, as provided in the Print Orders (R4
   File, Tab E).  The Army also informed the Appellant that it
   was forwarding "[m]atters regarding contractual discrepancies"
   to GPO "for review and possible modifications[.]" (R4 File,
   Tab E).

   6. On May 12, 1992, prior to receiving the Army's written
   confirmation of the page errors in the three Print Orders and
   instructions on how to proceed, the Appellant had already
   written to the Respondent requesting an equitable price
   adjustment and a contract modification for "reprinting of text
   pages due to [Army] errors[.]" (R4 File, Tab F).7  In that
   regard, the Contractor calculated its total price adjustment
   claim of $2,127.80, as follows:

      Print Order 40023-Reprint 16-page signature:

      II. C. 1. [Makeready and Set Up
          Charges]...................... $168.00
          C. 2. [Running Charges].......  332.80
                     Total   $500.80

      Print Order 40024-Reprint 32-page signature:

      II. C. 1. [Makeready and Set Up
          Charges]...................... $336.00
          C. 2. [Running Charges].......  665.00
                     Total   $1,001.00

      Print Order 40026-Reprint 16-page and 4-page signatures:

      II. C. 1. [Makeready and Set Up
          Charges]...................... $210.00
          C. 2. [Running Charges].......  416.00
                     Total   $626.00

See, R4 File, Tab F.  The running charges shown in Appellant's
claim represents the cost of reprinting the entire 4,000 copies
of each of the three DLPTBs affected by the camera copy error.

   7. On June 22, 1992, in response to the equitable adjustment
   claim, the Contracting Officer issued Contract Modification
   No. 1, and sent it to the Appellant for signature (R4 File,
   Tab G).  The proposed modification accepted the Contractor's
   makeready and set up charges, but rejected the Appellant's
   claim for reprinting the entire quantity of all three DLPTBs.
   As recomputed by the Contracting Officer, the Appellant was
   offered an equitable adjustment, as follows:

      Print Order 40023

      2 pieces of film @ $2.00 each..... $  4.00
      Makeready (16 pages @ $10.50
      each).............................. 168.00
      Running (4 copies of 16 pages
      @ .52 per 100 copies)..............    .33
                     Total   $172.33

      Print Order 40024

      2 pieces of film @ $2.00 each..... $  4.00
      Makeready (32 pages @ $10.50
      each).............................  336.00
      Running (4 copies of 32 pages
      @ .52 per 100 copies).............     .67
                     Total   $340.67

      Print Order 40026

      2 pieces of film @ $2.00 each..... $  4.00
      Makeready (20 pages @ $10.50
      each).............................  210.00
      Running (4 copies of 20 pages
      @ .52 per 100 copies).............     .42
                     Total   $214.42

See, R4 File, Tab G.  The total equitable price adjustment
recalculated by the Contracting Officer was $727.42 (R4 File, Tab
G).  The Contractor disagreed and refused to sign Contract
Modification No. 1.

   8. On July 2, 1992, after several telephone conversations
   between the parties about the proper amount of an equitable
   adjustment, the Contracting Officer issued a final decision
   disallowing the Appellant's overall claim of $2,127.80, and
   authorizing total reimbursements of $727.42, as computed in
   Contract Modification No. 1 (R4 File, Tab H).  The Contracting
   Officers reasoned, in pertinent part, as follows:

      On pages 5 and 6 of the contract specifications under
      "Prior to Production Samples" it states that the sample
      requirement is for not less than four serially numbered
      prior to production samples.  These four samples are to be
      submitted prior to the commencement of production of the
      contract production quantity.  These samples will be tested
      for conformance to specifications.  Manufacture of the
      final product prior to approval of the samples submitted is
      at the contractor's risk.  Therefore, I cannot allow your
      request for reprinting signatures for the whole print order
      quantities, since by the terms of the contract at this
      stage of production, you were only authorized to print four
      copies of each product.

   * * * * * * * * * *

      The total additional compensation authorized for your
      performance on these three [P]rint [O]rders is $727.42.
      The submission of the new camera copy for the six text
      pages was accomplished in accordance with Contract Clause
      4[,] Changes, GPO Contract Terms (GPO Pub. 310.2), which is
      a part of this contract.8

See, R4 File, Tab H, pp. 1, 2.  [Emphasis added.]

   9. The Contractor timely appealed the Contracting Officer's
   final decision to the Board.

   ISSUE PRESENTED

      Is the Appellant entitled to an equitable adjustment for
      reprinting the entire quantity of the DLPTBs affected by
      the page changes necessary to correct the errors in the
      camera copy furnished by the Government for Print Orders
      40023, 40024, and 40026, or is the Contracting Officer
      right in limiting the amount of the adjustment for each
      Print Order to a reprint of the four (4) copies required by
      the "Prior to Production Samples" specification of the IFB?

     POSITION OF THE PARTIES9


   Reduced to its essentials, this appeal involves the proper
   interpretation of the agreement between the parties, primarily
   the "Prior to Production Samples" clause of the contract.  The
   Appellant maintains that the plain meaning of so much of that
   clause which says that "[s]amples will be inspected and tested
   and must comply with the specifications as to construction,
   kind and quality of materials[.]," means that so long as the
   initial samples conformed to the original specifications, the
   Government was not at liberty to reject them simply because of
   an author's error.  Complaint, p. 1; RPC, p. 4.  Therefore,
   according to the Contractor, when the Army had to make page
   changes in the three affected DLPTBs because the original
   Government-furnished camera copy contained errors, the
   "Changes" clause of the contract allows full compensation for
   reprinting the text.  Complaint, p. 1.  Indeed, the Appellant
   notes that if the Government had not amended the initial
   samples, all of the DLPTBs it printed in anticipation of an
   "OK to print" would have been accepted and paid for by the
   Respondent.  RPC, pp. 4-5.  Furthermore, the Contractor
   contends that the customary practice in the trade is to print
   the entire quantity ordered to save costs, instead of first
   preparing pre-production samples and removing the job from the
   presses until the samples are approved for final printing.
   RPC, p. 5.  Accordingly, for these reasons, the Appellant
   believes that it is entitled to recover its entire equitable
   adjustment claim of $2,127.80.  Id.

   The Respondent, on the other hand, argues that the Appellant's
   interpretation of the contract is unsupported by the plain
   meaning of the words of the agreement.  R. Brf., p. 3; RPC, p.
   5.  In that regard, notwithstanding the Contractor's purported
   reliance on the industry practice of printing the entire
   ordered quantity at one time to save money, and its contention
   the Government must accept and pay for the entire quantity
   since the DLPTBs met the original specifications, GPO contends
   that the "Prior to Production Samples" clause of the contract
   clearly provides that: (1) samples shall be submitted to the
   Army "[p]rior to the commencement of production of the
   contract quantity, . . ."; and (2) the Contractor bears the
   risk of manufacturing the final product prior to approval of
   the sample.  R. Brf., p. 3 (citing, R4 File, Tab A, pp. 5-6).
   Furthermore, the Respondent points out that the "Films" clause
   of the contract expressly forbids the Contractor from printing
   prior to receipt of an "OK to print," and indeed, each Print
   Order warns that "[f]inal production is contingent upon
   approval of advance copies."  Id. (citing, R4 File, Tab A, p.
   5, Tab D).  Consequently, according to GPO, when the
   Appellant, in the face of these clear contractual clauses and
   provisions, printed all of the production quantities before
   receiving an "OK to print," it assumed responsibility for any
   additional costs which it incurred.  Id.    Finally, GPO
   argues that the "Changes" clause of the contract allowed the
   Government to correct the page errors and equitably adjust the
   contract price.  RPC, p. 4.  Accordingly, the Respondent
   believes that its adjustment offer to the Appellant of $727.42
   is equitable under the circumstances, and it asks the Board to
   affirm the Contracting Officer's decision.  R. Brf., p. 4;
   RPC, p. 4.

   CONCLUSIONS10

   As indicated previously, the single issue raised by the facts
   in this case can be resolved by a proper interpretation of the
   contract, especially the "Prior to Production Samples" clause.
   Since the parties have drawn different meanings from the
   disputed language, the Board's task is simple-it must decide
   which of the two conflicting interpretations is correct, or
   whether both readings may be reasonably derived from the
   contract terms; in other words, is the contract ambiguous?11
   Shepard Printing, GPO BCA 37-92 (January 28, 1994), Sl. op. at
   15-16.

   Since the focus of inquiry in this case is confined to the
   contract itself, see, RD Printing Associates, Inc., supra, Sl.
   op. at 9, 13, fns. 9 and 15; B. P. Printing and Office
   Supplies, GPO BCA 14-91 (August 10, 1992), Sl. op. at 15,
   certain legal principles should be kept in mind at the outset.
   When the parties confront the Board with two different
   interpretations of the same contract language they raise the
   possibility that the specifications may be ambiguous.  R.C.
   Swanson Printing and Typesetting Company, GPO BCA 31-90
   (February 6, 1992), Sl. op. at 41, aff'd on other grounds,
   Richard C. Swanson, T/A R.C. Swanson Printing and Typesetting
   Company v. United States, Cl.Ct. No. 92-128C (October 2,
   1992).  Contractual language is ambiguous if it will sustain
   more than one reasonable interpretation.12  Fry
   Communications, Inc./InfoConversion Joint Venture, GPO BCA
   9-85, Decision on Remand (August 5, 1991), Sl. op. at 9; R.C.
   Swanson Printing and Typesetting Company, supra, Sl. op. at
   41, fn. 22; General Business Forms, Inc., supra, Sl. op. at
   16.  See also, Fry Communications, Inc./InfoConversion Joint
   Venture v. United States, supra, 22 Cl.Ct. at 503 (citing,
   Edward R. Marden Corporation v. United States, 803 F.2d 701,
   705 (Fed. Cir. 1986); Sun Shipbuilding & Drydock Co. v. United
   States, 183 Ct.Cl. 358, 372 (1968)).  In analyzing disputed
   contract language, the courts and contract appeals boards
   place themselves in the shoes of a reasonably prudent
   contractor; i.e., the language of the contract must be given
   that meaning which a reasonably intelligent contractor
   acquainted with the circumstances surrounding the contract
   would derive.  General Business Forms, Inc., supra, Sl. op. at
   18 (citing, Salem Engineering and Construction Corporation v.
   United States, 2 Cl.Ct. 803, 806 (1983)).  See also, Norcoast
   Constructors, Inc. v. United States, 448 F.2d 1400, 1404, 196
   Ct.Cl. 1, 9 (1971); Firestone Tire and Rubber Company v.
   United States, 444 F.2d 547, 551, 195 Ct.Cl. 21, 30 (1971).

   A dispute over contract language is not resolved simply by a
   decision that an ambiguity exists-it is also necessary to
   determine whether the ambiguity is latent or patent.  Courts
   will find a latent ambiguity where the disputed language,
   without more, admits of two different reasonable
   interpretations.13  Fry Communications, Inc./InfoConversion
   Joint Venture v. United States, supra, 22 Cl.Ct. at 503
   (citing, Edward R. Marden Corporation v. United States, supra,
   803 F.2d at 705); R.C. Swanson Printing and Typesetting
   Company, supra, Sl. op. at 41, fn. 22.  On the other hand, a
   patent ambiguity would exist if the contract language
   contained a gross discrepancy, an obvious error in drafting,
   or a glaring gap, as seen through the eyes of a "reasonable
   man" on an ad hoc basis.14  Fry Communications,
   Inc./InfoConversion Joint Venture v. United States, supra, 22
   Cl.Ct. at 504 (citing, Max Drill, Inc. v. United States, 192
   Ct. Cl. 608, 626 (1970); WPC Enterprises, Inc. v. United
   States, 163 Ct.Cl. 1, 6 (1963)); General Business Forms, Inc.,
   supra, Sl. op. at 17 (citing, Enrico Roman, Inc. v. United
   States, supra, 2 Cl.Ct. at 106).

   However, the rules concerning ambiguous contract language come
   into play only if the meaning of the disputed terms are not
   susceptible to interpretation through the usual rules of
   contract construction.  Shepard Printing, supra, Sl. op. at
   19; R.C. Swanson Printing and Typesetting Company, supra, Sl.
   op. at 42.  The most basic principle of contract construction
   is that the document should be interpreted as a whole.15  Hol-
   Gar Manufacturing Corporation v. United States, 169 Ct.Cl.
   384, 388, 351 F.2d 972, 975 (1965); General Business Forms,
   Inc., supra, Sl. op. at 16; Restatement (Second) Contracts, 
   202(2) (1981).  Hence, all provisions of a contract should be
   given effect and no provision is to be rendered meaningless.
   Pacificorp Capital, Inc. v. United States, supra, 25 Cl.Ct. at
   716; United States v. Johnson Controls, Inc., 713 F.2d 1541,
   1555 (Fed. Cir. 1983); Fortec Constructors v. United States,
   760 F.2d 1288, 1292 (Fed. Cir. 1985); Jamsar, Inc. v. United
   States, 442 F.2d 930 (Ct.Cl. 1971); Grace Industries, Inc.,
   ASBCA No. 33553, 87-3 BCA  20,171; General Business Forms,
   Inc., supra, Sl. op. at 16 (citing, Raytheon Company v. United
   States, 2 Cl.Ct. 763 (1983)).  In other words, a contract
   should be interpreted in a manner which gives meaning to all
   of its parts and in such a fashion that the provisions do not
   conflict with each other, if this is reasonably possible.16
   B. D. Click Company v. United States, 614 F.2d 748 (Ct.Cl.
   1980).  When these principles to the facts in the record, it
   is clear that:

      The Appellant assumed the risk of printing all of the
      DLPTBs before receiving the required approval from the
      Government.  Therefore, the Contractor must bear the cost
      of its premature unilateral act, and is not entitled to an
      equitable adjustment based on its reprinting of the entire
      order.  Accordingly, the Contracting Officer correctly
      limited the amount of the Appellant's adjustment solely to
      the cost of reprinting the four (4) advance copies required
      by the "Prior to Production Samples" clause for each of the
      three Print Orders affected by the page changes.



   This is a very simple case.  Notwithstanding the painstaking
   efforts of the Appellant to construe the contract's "Prior to
   Production Samples" clause, the Board does not see any
   ambiguity in its terms.  Cf., Shepard Printing, supra, Sl. op.
   at 20; R.C. Swanson Printing and Typesetting Company, supra,
   Sl. op. at 43-44; Export Packing & Crating Company, ASBCA No.
   16133, 73-2 BCA  10,066, at 47,215.  In the Board's view,
   nothing could be clearer than the express requirements of that
   clause which state that samples should be submitted "[p]rior
   to the commencement of production of the contract quantity,"
   and "in sufficient time to allow Government testing . . . and
   production . . . in accordance with the shipping schedule,"
   and that "[m]anufacture of the final product prior to approval
   of the sample submitted is at the contractor's risk[.]" (R4
   File, Tab A, pp. 5-6).   Furthermore, as if that is not
   enough, the "Films" clause provides that "[t]he contractor
   must not print prior to receipt of any 'OK to print[.]'," and
   each Print Order says, in capital letters, that "[f]inal
   production is contingent upon approval of advance copies[.]"
   (R4 File, Tab A, p. 5 and Tab D).  There is nothing obtuse or
   hazy about this language.  No conjecture or speculation is
   necessary to interpret these contract words and terms.  They
   are clear ex facie, and mean what they say.  Thus, the
   documentary record is peppered with numerous "yellow lights"
   cautioning the Contractor not to print the entire ordered
   quantity of DLPTBs unless and until an "OK to print" has been
   given following the review and approval of the sample advance
   copies by the Government.  A reasonably aware contractor
   ignores these warnings at its peril.
   There is a paucity of cases in the Board's volumes concerning
   premature printing by GPO contractors.  The Board's exhaustive
   research of its own decisions and those of its predecessor ad
   hoc panels,17 reveals only one case analogous to the present
   situation-Serigraphic Arts, Inc., GPOCAB 22-79 (May 8, 1980).
   In that case, the contractor appealed a final decision denying
   its claim for certain additional costs associated with its
   printing of 465,000 numbered, pressure sensitive adhesive
   decals for the Department of Transportation (DOT).  The
   contract in dispute contained a "Proofs" clause which required
   the contractor, in pertinent part to:

      Submit 5 proofs of each item representative of the finished
      product per these specifications (unnumbered) along with
      the furnished copy for approval before printing . . .
      Submit the proofs as soon as possible to allow for the
      possibility of necessary corrections.  The proofs are
      scheduled to be back at the contractor's plant within 9
      working days after receipt at the GPO.

Serigraphic Arts, Inc., supra, Sl. op. at 6.  Although the
proofs, as originally submitted by the contractor, complied with
the contract specifications, DOT requested a substantial color
change.  However, because the contractor misunderstood a
telephone conversation it had with a GPO employee (not the
contracting officer), it thought it had been given verbal
approval to print the job in accordance with the original proofs,
and did so before it received the amended proofs back from GPO.
Consequently, after reprinting the decals, as changed, the
contractor alleged that it had incurred extra costs amounting to
over $5,000.00 which, in addition to the contract price, the
Government should pay.  The contracting officer disagreed,
contending that since the contractor had not been authorized to
print the job as provided for by the procedures within the
contract specifications, the additional costs which it had
incurred by printing the contract prematurely could not be
reimbursed.  Affirming the contracting officer's denial of the
claim for additional costs, the ad hoc panel pointed to the
"Proofs" clause and reasoned:

      . . .[T]o make sense of the first sentence of this
      provision it is necessary to read it in conjunction with
      the rest of the contract clause.  Daniel H. Foster, Jr.,
      ASBCA No. 21965, 78-2 BCA  13,541, on reconsideration,
      79-2 BCA  14,161.  If verbal approval of the proofs would
      have been sufficient to begin to print then it would not
      have been necessary for the GPO to return the proofs to the
      contractor within a certain number of days as required by
      the last sentence of the clause.  When one reads the entire
      clause together, the reasonable interpretation is that the
      contractor must receive the proofs prior to printing.  To
      begin printing without such authorization is to act
      unilaterally and to assume the risk of incorrectly
      interpreting the contract.  California Shipbuilding and Dry
      Dock Company, ASBCA No. 21394, 78-1 BCA  13,168.

      . . . [The contractor's] action, albeit taken under the
      time limitations of the contract, risked the possibility
      that some alteration of the proofs would be necessary.

Serigraphic Arts, Inc., supra, Sl. op. at 7-8.  [Emphasis added.]
As indicated in the ad hoc panel's decision, the rule which
allocates the risk of a contractor's disregard of contract
specifications and resulting premature performance to the
contractor, is consistently applied in Government contract law.
See, e.g., Hobbs Construction and Developement, Inc., ASBCA Nos.
30432, 32151, 91-2 BCA  24,014; Gibson Hart Company, VABCA No.
2847, 89-2 BCA  21,830.

   The only explanation offered by the Appellant for prematurely
   printing the entire ordered quantity of DLPTBs in this case is
   its contention that it followed the customary practice in the
   trade to save costs.  RPC, p. 5.  However, as previously
   mentioned, the settled rule of construction is that custom and
   trade usage may not contradict clear or unambiguous terms.18
   WRB Corporation v. United States, supra, 183 Ct.Cl. at 436.
   Furthermore, in a recent decision the Board rejected a
   contractor's argument based upon its adherence to the
   commercial standards of the private sector, on the ground that
   they are of no relevance in a Government procurement.
   Sterling Printing, Inc., GPO BCA 20-89 (March 28, 1994), Sl.
   op. at 25, fn. 38.  Thus, the Board believes that the
   Appellant's alleged reliance on industry practice as an excuse
   for disregarding the express specifications in its contract,
   even if true, is not enough to shift risk of its premature act
   to the Government, especially in light of well-settled
   procurement law principles.19  See, e.g., Hobbs Construction
   and Developement, Inc., supra, 91-2 BCA  24,014; Gibson Hart
   Company, supra, 89-2 BCA  21,830; Serigraphic Arts, Inc.,
   supra.

   In the final analysis, the Board believes that this case is a
   rarity in the annals of the Board and the ad hoc panels,
   because the meaning of the key contract provisions are so
   obvious that a reasonable contractor could have no doubt as to
   their meaning-they are impossible to misconstrue or
   misunderstand.  The only reasonable reading of the relevant
   contractual words and phrases discloses a production sequence
   under which the Appellant was not authorized to print the
   entire ordered quantity of DLPTBs until it was expressly told
   to do so by receipt of an "OK to print" following the review
   and approval of the pre-production samples by the Government.
   Furthermore, the Contractor was expressly told that it bore
   the risk of final performance in advance of such approval.
   This contract language is so clear as to warrant no contrary
   interpretation.  Indeed, any construction that shifts the risk
   of premature performance to the Government in light of this
   language, would not merely strain the contract, it would
   rewrite it.  The Board is not only unwilling to distort the
   contract language in this case, but even if it had a mind to
   do so, it lacks the authority to amend the agreement.  Cf.,
   Shepard Printing, supra, Sl. op. at 9, fn. 8; The Wessel
   Company, Inc., supra, Sl. op. at 32-33; Bay Printing, Inc.,
   GPO BCA 16-85 (January 30, 1987), Sl. op. at 9; Peake
   Printers, Inc., GPO BCA 12-85 (November 12, 1986), Sl. op. at
   6.

   Lastly, it should be clear that although the contract and the
   Print Orders were drafted by the Respondent, the ultimate
   beneficiary of strict adherence to the relevant language
   should have been the Appellant.  In the Board's view, the
   contractual procedure was there to protect against just the
   sort of increased costs experienced by the Contractor when, as
   here, the Government, for whatever reason, makes changes to
   the product after examining the original sample.  Since the
   Appellant chose to disregard these provisions, under the
   express terms of the contract, it assumed the risk of any
   increased costs which might have occurred from those changes.
   Accordingly, the appeal is denied in its entirety.

              ORDER

     The Board finds and concludes that by printing the entire
     quantity of DLPTBs before receiving the required approval
     from the Government, the Appellant, in accordance with the
     express language of the contract and the Print Orders,
     assumed the risk and bears the cost of its premature
     unilateral act.  THEREFORE, the decision of the Contracting
     officer is AFFIRMED, and the appeal is DENIED.20

It is so Ordered.

April 11, 1994                  STUART M. FOSS
                        Administrative Judge
_______________

    1 The Contracting Officer's appeal file, assembled pursuant
    to Rule 4 of the Board's Rules of Practice and Procedure, was
    delivered to the Board on August 28, 1992.  GPO Instruction
    110.12, Subject: Board of Contract Appeals Rules of Practice
    and Procedure, dated September 17, 1984, Rule 4(a) (Board
    Rules).  It will be referred to hereinafter as the R4 File,
    with an appropriate Tab letter also indicated.  The R4 File
    consists of eight (8) documents identified as Tabs A through
    H.
    2 By letter dated September 17, 1992, the Appellant advised
    the Board that it had selected the optional Accelerated
    Procedure to process its appeal.  Board Rules, Rules 12.1(b)
    and 12.3.
    3 Decisions under the Accelerated Procedure are normally
    brief and contain only summary findings of fact and
    conclusions.  Board Rules, Rule 12.3(b).  In this case,
    however, the Board believes that the nature of the
    controversy entitles the parties to a fuller explanation of
    the facts, issues, and reasons for the Board's decision than
    would be found in a typical Accelerated Procedure case.  See,
    McDonald & Eudy Printers, Inc., GPO BCA 40-92 (January 31,
    1994), Sl. op. at 2, fn. 3; Shepard Printing, GPO BCA 37-92
    (January 28, 1994), Sl. op. at 2, fn. 3; Hurt's Printing
    Company, Inc., GPO BCA 27-92 (January 19, 1994), Sl. op. at
    2, fn. 3.  The Board also notes that this decision, unlike
    its opinions under the Small Claims (Expedited) Procedure,
    may be cited as precedent in future appeals. Cf., Graphics
    Image, Inc., GPO BCA 13-92 (August 31, 1992), Sl. op. at 2,
    fn. 3; Board Rules, Rule 12.2(d).
    4 The "Ordering" clause of the contract provided, in
    pertinent part, that: "Items to be purchased under the
    contract shall be ordered by the issuance of print orders by
    the Government[.]" (R4 File, Tab A, p. 4).  Furthermore, the
    contract was a "direct-deal" arrangement, and the Army was
    responsible for issuance of the Print Orders during the term
    of the agreement (R4 File, Tab A, p. 3).  See, Printing
    Procurement Regulation, GPO Publication 305.3 (September 1,
    1988), Chap. XII, Sec. 1,  2 (hereinafter PPR).
    5 Apart from the usual specifications pertaining to printing,
    binding and delivery of the publications in question, the
    contract was also governed by applicable articles of GPO
    Contract Terms, GPO Publication 310.2, effective December 1,
    1987 (Rev. 9-88) (GPO Contract Terms), and GPO's Quality
    Assurance Through Attributes Program, GPO Publication 310.1,
    effective May 1979 (revised November 1989) (QATAP), which
    were incorporated by reference in the Purchase Order (R4
    File, Tab A, p. 2).
    6 Tab E is a letter from the Army to the Appellant, dated May
    27, 1992, confirming a previous conversation concerning the
    page errors discovered in the proofs furnished under the
    three Print Orders.  The letter refers to Print Orders 40020
    through 40027, and except for the three in dispute, approves
    the others-Print Orders 40020, 40021, 40022, 40025, and
    40027-for printing and distribution (R4 File, Tab E).
    7 Tab F refers to an attached letter from the Army, which is
    not part of the file.  Tab E contains the only letter from
    the Army in the record, and it is dated May 27, 1992, or 15
    days later than the Appellant's correspondence seeking an
    equitable adjustment.  See, note 6 supra.
    8 See, note 5 supra.  The standard GPO "Changes" clause
    provides, in pertinent part: "(a) The Contracting Officer may
    at any time, by written order, . . . , make changes within
    the general scope of this contract in . . . (1) Drawings,
    designs, or specifications when the supplies to be furnished
    are to be specially manufactured for the Government in
    accordance with the drawings, designs, or specifications. . .
    .(b) If any such change causes an increase or decrease in the
    cost of, or the time required for, performance of any part of
    the work, whether or not changed by the order, the
    Contracting Officer shall make an equitable adjustment in the
    contract price, the delivery schedule, or both, and shall
    modify the contract."  GPO Contract Terms, Contract Clauses,
     4(a),(b) (Changes).
    9 Only the Respondent submitted a written brief in this
    appeal.  See, Respondent's Brief, dated March 1, 1993
    (hereinafter R. Brf.).  The Board's understanding of the
    positions of the parties is based on the Appellant's
    Complaint, dated July 22, 1992, the Respondent's Answer,
    dated October 19, 1992, the discussions at the presubmission
    conference on December 8, 1992, as reflected in the Report of
    Presubmission Conference, dated February 17, 1993
    (hereinafter RPC), and the Respondent's brief.
    10 The record on which the Board's decision is based consists
    of: (1) the Appellant's letter, dated July 22, 1992, noting
    an appeal from the Contracting Officer's decision and
    containing its Complaint; (2) the R4 File (Tabs A-H); (3) the
    Respondent's Answer, dated October 19, 1992; (4) the Report
    of Presubmission Conference, dated February 17, 1993; and (5)
    the Respondent's Brief of March 1, 1993.
    11 Contract interpretation is clearly a question of law, see,
    e.g., Pacificorp Capital, Inc. v. United States, 25 Cl.Ct.
    707, 715 (1992), aff'd 988 F.2d 130 (Fed. Cir. 1993); Fortec
    Contractors v. United States, 760 F.2d 1288, 1291 (Fed.Cir.
    1985); P.J. Maffei Building Wrecking Company v. United
    States, 732 F.2d 913, 916 (Fed. Cir. 1984); Fry
    Communications, Inc.-InfoConversion Joint Venture v. United
    States, 22 Cl.Ct. 497, 503 (Cl.Ct. 1991); Hol-Gar Mfg. Corp.
    v. United States, 169 Ct.Cl. 384, 386, 351 F.2d 972, 973
    (1965); General Business Forms, Inc., GPO BCA 2-84 (December
    3, 1985), Sl. op. at 16 (citing, John C. Grimberg Company v.
    United States, 7 Ct.Cl. 452 (1985)); RD Printing Associates,
    Inc., GPO BCA 02-92 (December 16, 1992), Sl. op. at 13, as is
    definition of the contract.  See, Ralph Construction, Inc. v.
    United States, 4 Cl.Ct. 727, 731 (1984) (citing, Torncello v.
    United States, 681 F.2d 756, 760 (Ct.Cl. 1982).  Any decision
    by this Board concerning such a matter is reviewable by the
    Courts under the Wunderlich Act, 41 U.S.C.  321, 322.  Fry
    Communications, Inc./ InfoConversion Joint Venture v. United
    States, supra, 22 Cl.Ct. at 501, fn. 6; General Business
    Forms, Inc., supra, Sl. op. at 16.
    12 The United States Claims Court has observed that: "[a]
    mere dispute over the terms does not constitute an ambiguity,
    and an interpretation which is merely possible is not
    necessarily reasonable."  Ceccanti, Inc. v. United States, 6
    Cl.Ct. 526, 528 (1984).  An ambiguity must have two or more
    reasonable interpretations and the intent of the parties must
    not be determinable by the normal rules of interpretation.
    R.C. Swanson Printing and Typesetting Company, supra, Sl. op.
    at 42.
    13 In such cases, the doctrine of contra proferentem applies
    and the dispute language will be construed against the
    drafter, Fry Communications, Inc./InfoConversion Joint
    Venture v. United States, supra, 22 Cl.Ct. at 503 (citing,
    William F. Klingensmith, Inc. v. United States, 205 Ct.Cl.
    651, 657 (1974)); R.C. Swanson Printing and Typesetting
    Company, supra, Sl. op. at 41, fn. 22, if the non-drafter can
    show that he/she relied on the alternative reasonable
    interpretation in submitting his/her bid.  Fry
    Communications, Inc./ InfoConversion Joint Venture v. United
    States, supra, 22 Cl.Ct. at 510 (citing, Fruin-Colon
    Corporation v. United States, 912 F.2d 1426, 1430 (Fed. Cir.
    1990)); Lear Siegler Management Services v. United States,
    867 F.2d 600, 603 (Fed. Cir. 1989).
    14 Where there are such discrepancies, errors, or gaps, the
    contractor has an affirmative obligation to ask the
    contracting officer to clarify the true meaning of the
    contract language before submitting its bid.  Fry
    Communications, Inc./InfoConversion Joint Venture v. United
    States, supra, 22 Cl.Ct. at 504 (citing, Newsom v. United
    States, 230 Ct.Cl. 301, 303 (1982)); Enrico Roman, Inc. v.
    United States, 2 Cl.Ct. 104, 106 (1983); S.O.G. of Arkansas
    v. United States, 546 F.2d 367, 212 Ct.Cl. 125 (1976); Beacon
    Construction v. United States, 314 F.2d 501 (Ct.Cl. 1963).
    15 The purpose of any rule of contract interpretation is to
    carry out the intent of the parties.  Hegeman-Harris and
    Company, 440 F.2d 1009 (Ct.Cl. 1979).  The test for
    ascertaining intent is an objective one; i.e., the question
    is what would a reasonable contractor have understood, not
    what did the drafter subjectively intend.  Corbetta
    Construction Company v. United States, 461 F.2d 1330, 198
    Ct.Cl. 712 (1972).  See also, Salem Engineering and
    Construction Corporation v. United States, 2 Cl.Ct. 803, 806
    (1983).  The provisions of the contract itself should provide
    the evidence of the objective intent of the parties.
    16 It is unnecessary to set forth in detail the rules of
    contract construction which apply when interpreting an
    agreement.  Suffice it to say that, within the contract
    itself, ordinary terms are to be given their plain and
    ordinary meaning in defining the rights and obligations of
    the parties.  Elden v. United States, 617 F.2d 254, 223
    Ct.Cl. 239 (1980).  Similarly, technical terms are given
    their technical meaning.  Coastal Drydock and Repair
    Corporation, ASBCA No. 31894, 87-1 BCA  19,618; Industrial
    Finishers, Inc., ASBCA No. 6537, 61-1 BCA  3,091.  Likewise,
    terms special to Government contracts will be given their
    technical meanings.  General Builders Supply Company v.
    United States, 409 F.2d 246, 187 Ct. Cl. 477 (1969) (meaning
    of "equitable adjustment").  As for extrinsic evidence of the
    intent of the parties, the rules of construction allow, among
    other things, custom and trade usage to explain or define
    terms.  W. G. Cornell Company v. United States, 376 F.2d 199,
    179 Ct. Cl. 651 (1967);  Harold Bailey Painting Company,
    ASBCA No. 27064, 87-1 BCA  19,601 (used to define "spot
    painting").  However, custom and trade usage may not
    contradict clear or unambiguous terms.  WRB Corporation v.
    United States, 183 Ct.Cl. 409, 436 (1968).  On the other
    hand, the Board is not bound by what the parties call a
    contract,  Ralph Construction, Inc. v. United States, supra,
    4 Cl.Ct. at 731 (citing, Torncello v. United States, supra,
    681 F.2d at 760; Mason v. United States, 222 Ct.Cl. 436, 444,
    615 F.2d 1343, 1346-47 (1980)), and the understanding and
    actions of officials administering an agreement are not
    dispositive, Salem Engineering & Construction Corporation v.
    United States, supra, 2 Cl.Ct. at 808.
    17 The Board was created by the Public Printer in 1984.  GPO
    Instruction 110.10C, Subject: Establishment of the Board of
    Contract Appeals, dated September 17, 1984.  Prior to that
    time, appeals from decisions of GPO Contracting Officers were
    considered by ad hoc panels of its predecessor, the GPO
    Contract Appeals Board (GPOCAB). The Board has consistently
    taken the position that it is a different entity from the
    GPOCAB.  See, The Wessel Company, Inc.,  GPO BCA 8-90
    (February 28, 1992), Sl. op. at 25, fn. 25.  Nonetheless, it
    has also been the Board's policy to follow the holdings of
    the ad hoc panels where applicable and appropriate, but the
    Board differentiates between its decisions and the opinions
    of those panels by citing the latter as GPOCAB.  See, e.g.,
    Shepard Printing, supra, Sl. op. at 11, fn. 10; Stephenson,
    Inc., GPO BCA 02-88 (December 20, 1991), Sl. op. at 18, fn.
    20; Chavis and Chavis Printing, GPO BCA 20-90 (February 6,
    1991), Sl. op. at 9, fn. 9.
    18 See, note 16 supra.
    19 The Appellant's belief that as long as the initial samples
    conformed to the original specifications, the Government was
    prevented from rejecting them merely because of an author's
    error, and thus the Contractor is entitled to full
    compensation under the "Changes" clause for reprinting the
    text, Complaint, p. 1, RPC, pp. 4-5, is simply so without
    merit as to warrant no discussion.  Serigraphic Arts, Inc.,
    supra, Sl. op. at 7-8.  Under the Appellant's theory, the
    Government could never correct an honest error without, in
    effect, paying double for the privilege of doing so.  The
    Board finds no basis in Government procurement law for
    assessing such a penalty where, as here, the Government is
    acting in accordance with the contract, and it is the
    contractor who has ignored the express language of the
    specifications.
    20 In the absence of any evidence in the record whatsoever to
    the contrary, the Board accepts the Contracting Officer's
    determination that $727.42 was a reasonable equitable
    adjustment in this case.  Cf., McDonald & Eudy Printers,
    Inc., GPO BCA 9-88 (March 8, 1990), Sl. Op. at 1.