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.