Current Printing Practices Show Changes since 1990

Since the JCP Regulations were updated in 1990, agencies’ printing  operations have changed in scale and type. Fewer In-house Printing Plants Are in Operation Than in 1990

Based on definitions we developed in conjunction with GPO and the  Interagency Council on Printing and Publication Services, among the  agencies in our survey universe, we measured 64 percent fewer in-house  printing plants than the number included in the 1990 JCP Regulations. DOD accounted for the greatest decline in in-house printing plants. For  example, the 1990 JCP Regulations listed 142 in-house printing plants for  the armed services and the Defense Logistics Agency (DLA), which  currently manages the majority of DOD’s printing infrastructure. This executive  order included a provision encouraging agencies “to limit the publication  and printing of hard copy documents and to presume that information  should be provided in an electronic form, whenever practicable, permitted  by law, and consistent with applicable records retention requirements.”

		Agencies Reported Operating Primarily Duplication Equipment at In-house Printing Plants

The vast majority of agencies that currently operate in-house printing  plants reported operating duplication equipment. That is, most agencies  reported operating high-speed duplication machines, and fewer reported  operating conventional printing presses. Of the 32 agencies operating in- house printing plants, 17 reported that all of their in-house printing was  duplication, and another 14 agencies reported operating some duplication  equipment in addition to ink-based conventional printing presses. The  remaining agency did not report its type of equipment (see fig. No  agency reported having only ink-based conventional printing presses at  its in-house plants. In addition to agencies operating fewer printing plants and conducting  more duplication, interviews with selected agencies showed declines in  printing volumes in recent years. All six agencies  also reported greater spending on printing sent to GPO and private  printers than on in-house printing or duplication. Current Printing Practices Are Not Fully Reflected in Existing Printing Authorities

		1990 JCP Regulations

Even with these changes in agencies’ printing, the definition of “printing”  has not been updated in the 1990 JCP Regulations, which outline  printing-related definitions and list authorized agency in-house printing  plants. In 1994, Title 44 was updated to include “duplicating” in the  definition of “printing,” so that it read “… ‘printing’ includes the processes  of composition, platemaking, presswork, duplicating, silk screen  processes, binding, microform, and the end items of such processes.”  However, the 1990 JCP Regulations have not been updated to include  duplicating in the definition of printing, and duplicating is not separately  defined in either authority. In addition, the 1990 JCP Regulations provide that federal agencies  report on their print operations to the JCP, but the requirements do not  address duplication. The majority of government documents are published digitally  (electronically produced and then disseminated over the Internet);  however, the provisions in the law that require agencies to submit  documents to the Federal Depository Library Program (FDLP) do not  reference digital publishing. Officials from selected agencies told us  they do not submit digital documents to FDLP, and two reported that  they do not have any policies or procedures for submitting documents to  the FDLP regardless of whether the documents were printed at their in- house printing plants or published electronically. FDLP staff have taken a number of steps to address this challenge, and  to obtain digital documents from agencies. In a January 2013 report, the National Academy of Public  Administration (NAPA) recommended that GPO work with depository  libraries and other library groups to develop a comprehensive plan for  preserving the print collection of government documents, including a  process for ingesting digitized copies into FDsys, GPO’s online system  that provides free access to government publications. Agency Comments

We provided copies of our draft report to GPO and DOD for their review  and comment. GPO generally agreed with our findings and provided a  letter and technical comments, which we incorporated as appropriate. DOD did not provide comments. This includes using this data to select agencies to  survey. To describe how federal printing regulations and statutes reflect current  printing practices, we reviewed legal documents such as Title 44 of the  U.S. Code and the 1990 JCP Regulations, administered a survey to the  universe of agencies described above, and interviewed officials from the  printing industry, GPO, and other federal agencies. Duplicating includes high-speed duplicating. 2.
Why GAO Did This Study

Federal law requires that, with limited exceptions, all federal printing be performed by or through GPO. The JCP authorizes exemptions to specific agencies to operate in-house printing plants. In its 1990 JCP Regulations, the JCP included a list of authorized federal in-house printing plants. Some agency documents, once published, are required to be submitted to the FDLP, a GPO program designed to preserve government documents and make them available to the public.
GAO was asked to examine how federal printing practices had changed since the JCP Regulations were updated in 1990. This report describes (1) agencies' current printing practices--including the number of in-house printing plant and selected agencies' volumes and spending--and (2) how agencies' current printing practices are reflected in federal printing regulations and statutes.
GAO surveyed agencies that might be operating in-house printing plants, interviewed GPO and agency officials, analyzed agency data on printing volumes and spending, and reviewed printing regulations and statutes. GAO also selected six agencies from those surveyed to interview, based on their printing and reproduction obligations. Findings from these interviews cannot be generalized to other federal agencies.
GAO is not making recommendations in this report. GAO provided copies of the draft report to GPO and DOD for review and comment. GPO generally agreed with the findings and provided a letter and technical comments which were incorporated as appropriate. DOD did not provide comments.

What GAO Found

Agencies GAO surveyed reported operating fewer in-house printing plants than in 1990. Specifically, surveyed agencies reported operating 64 percent fewer plants than the number listed in the Congress's Joint Committee on Printing's (JCP) Government Printing and Binding Regulations, updated in 1990 (1990 JCP Regulations). The Department of Defense (DOD) accounted for the greatest decline in in-house printing plants. The 1990 JCP Regulations listed 142 DOD printing plants; however, the Defense Logistics Agency, which currently manages the majority of DOD's printing infrastructure, reported 17 in-house printing plants in GAO's survey. In addition, most agencies reported operating toner-based high-speed duplication machines, and fewer reported operating ink-based conventional printing presses. Of the 32 agencies operating in-house printing plants, 17 reported that all of their in-house printing was conducted on high-speed duplication machines; another 14 agencies reported operating some duplication equipment in addition to conventional printing presses (the remaining agency did not report its type of equipment). No agency reported having only ink-based conventional printing presses at its in-house plants. In addition, interviews with selected agencies showed declines in printing volumes and total spending, and suggested that agencies spent more on printing sent to the Government Printing Office (GPO) and its contracted private printers than on printing done at in-house printing plants.
Agencies' printing practices have changed, but existing authorities have not been updated. For example, in 1994, Title 44 of the U.S Code was updated to include "duplicating" in the definition of "printing," but the 1990 JCP Regulations do not include this definition. According to JCP staff, the Committee is aware that the 1990 JCP Regulations do not include duplicating in the definition of printing, and the Committee is working to revise the guidance. Also, the majority of government documents are now published digitally, but provisions in Title 44 that require agencies to submit documents to the Federal Depository Library Program (FDLP) do not reference digital publishing. Selected agencies GAO interviewed reported that they do not submit digital documents to FDLP. FDLP staff have taken a number of steps to address this, including educating agencies about FDLP requirements. In addition, the National Academy of Public Administration recently recommended that GPO develop a plan to preserve and collect government documents, and include a process for ingesting digitized copies into GPO's online government publications system, and GPO reported that it would incorporate this recommendation into its national plan for the future of the FDLP.