BNUMBER:  B-280405             
DATE:  August 24, 1998
TITLE: Caddell Construction Company, Inc., B-280405, August 24, 1998
**********************************************************************

Matter of:Caddell Construction Company, Inc.

File:B-280405            
        
Date:August 24, 1998

Timothy Sullivan, Esq., and Katherine S. Nucci, Esq., Adduci, 
Mastriani & Schaumberg, for the protester. 
Edward P. Meyerson, Esq., and Stanley W. Logan, Esq., Berkowitz, 
Lefkovits, Isom & Kushner, and Laurence Schor, Esq., McManus, Schor, 
Asmar & Darden, for Bill Harbert Construction Company, an intervenor. 
Carlton A. Arnold, Esq., and Robert W. Pessolano, Esq., Department of 
the Army, for the agency. 
Adam Vodraska, Esq., and James A. Spangenberg, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Contracting agency reasonably rejected hand-carried proposal as late 
where a preponderance of the evidence establishes that the protester 
did not deliver the proposal to the designated location prior to the 
time set for closing.

DECISION

Caddell Construction Company, Inc. protests the rejection of its 
proposal as late under request for proposals (RFP) No. 
DACA27-98-R-0020, issued by the U.S. Army Corps of Engineers, 
Louisville District, for construction of the 3rd Brigade Barracks 
Complex, Phase III, at Fort Campbell, Kentucky.[1]

We deny the protest.

BACKGROUND

The RFP required offerors to submit their original proposals, and the 
requisite number of copies, to Room 821 of the Corps of Engineers 
offices at 600 Dr. Martin Luther King, Jr. Place (the Federal 
Building), Louisville, Kentucky, no later than 4:30 p.m. local time, 
April 21, 1998.  RFP at A-1, L-7.  The solicitation included the full 
text of the late proposal provision of the standard "Instructions to 
Offerors--Competitive Acquisition (Oct 1997)," Federal Acquisition 
Regulation (FAR)
 sec.  52.215-1(c)(3).  RFP at L-3.  

The agency received a proposal from Bill Harbert Construction Company 
prior to the 4:30 p.m. closing time,[2] but maintains that it did not 
receive Caddell's proposal until after 4:30 p.m., when the Chief of 
Contracting for the Louisville District accepted Caddell's proposal 
(noting that it was late) from Caddell employees who had been denied 
entry to Room 821 when the doors to that room were locked by agency 
personnel at 4:30 p.m.  The Corps subsequently rejected Caddell's 
proposal as late because its late submission did not meet any of the 
criteria of FAR  sec.  52.215-1(c)(3) for acceptance of late proposals.  
Caddell then filed an agency-level protest, which the Corps denied on 
June 9.  This protest followed.  

Caddell contends that its employees reached the door to Room 821 with 
its proposal at 4:29 p.m., and thus prior to the 4:30 p.m. deadline, 
but that agency personnel did not allow Caddell to timely submit its 
proposal because they prematurely locked the door to Room 821, 
apparently because they earlier used one clock to advise a Caddell 
representative of the time (which he used to synchronize his watch 
while finalizing Caddell's proposal), but then used a different 
time-keeping device to determine that the proposal submission deadline 
had passed.  Caddell attributes the incident to the lack of an 
"official clock" in plain view, on which the Corps could base its 
determination that the deadline had arrived and by which offerors 
could verify the time.  The Corps, supported by the intervenor, 
Harbert, counters that the evidence does not support Caddell's 
contention that its employees reached Room 821 prior to 4:30 p.m. and 
maintains that agency personnel did not use different times or 
prematurely lock the door to the room where proposals were to be 
submitted.

In view of the inconsistencies among the protester's, the agency's, 
and the intervenor's accounts of the events of April 21, our Office 
conducted a hearing at the Corps's offices in Louisville to ascertain 
the facts and to assess the credibility of the respective parties' 
witnesses to the events of that day.

The reception area of Room 821, which contains the contracting offices 
of
the Louisville District, is a large space broken up by numerous 
cubicles. 
A receptionist's desk faces the main door to Room 821, which is a 
glass door opening onto a hallway.  On the receptionist's desk is a 
telephone with a digital clock, a personal computer, and a time/date 
stamp machine which audibly clicks on the minute every 60 seconds as 
the minutes advance.  Hearing Transcript (Tr.) at 5-10.  The official 
time used by the contracting division is that kept by the time/date 
stamp machine.  Tr. at 5-6, 216, 269; Agency Report at  para.  4.  The 
time/date stamp machine does not have a clock face.  Protest at 9 n.1; 
Agency Report at
 para.  4, 26.  The receptionist, Connie Senne, testified that to tell the 
time she synchronizes the time/date stamp machine with the digital 
clock displayed on her telephone (hereinafter "clock").  Tr. at 5-8, 
269-70.  She explained that to do so she sticks a piece of paper into 
the time/date stamp machine, obtains a stamp of the time 
(hours/minutes), sets the clock 1 minute ahead of the time/date stamp, 
and then activates the clock when she hears the time/date stamp 
machine click to the next minute, ensuring that when the time/date 
machine next clicks the clock will read the same hour and minute.  Tr. 
at 8-9, 269-70.  Ms. Senne testified that on the day proposals were 
due, April 21, she did not need to adjust the time on her clock with 
the time of the time/date stamp machine because they were already 
synchronized.  Tr. at 298.

Across from the receptionist's area in Room 821 near the door to the 
hallway is the cubicle of Linda Hunt-Smith, a contract specialist who 
was the designated proposal receiving agent for this RFP.  Her desk 
holds a telephone with a digital clock and her personal computer.  Tr. 
at 12-13.  Ms. Hunt-Smith testified that when she first arrived at 
work on the day proposals were due she called the time service on the 
telephone and checked it with the time/date stamp, her computer, and 
her clock to verify that all times read the same.  Tr. at 214.  To 
verify that the time/date stamp machine was synchronized with her 
clock, Ms. Hunt-Smith had Ms. Senne insert a piece of paper in the 
time/date stamp machine and read aloud the time indicated on the 
resulting stamp.  Tr. at 213.  When the machine clicked to the next 
minute, Ms. Hunt-Smith obtained another readout from Ms. Senne of the 
time on the time/date stamp machine in order to verify that their 
clocks read the same.
Tr. at 214.  Both Ms. Senne and Ms. Hunt-Smith testified that they 
checked the synchronization of Ms. Hunt-Smith's clock in this manner 
several times on 
April 21.  Tr. at 11-12, 214.

At approximately 3 p.m., two Caddell employees, Dick Greaves and James 
Gage, arrived at Room 821 of the Corps's offices, introduced 
themselves to the receptionist, and were directed to Ms. Hunt-Smith.  
Tr. at 73-75, 138-40.  The Caddell employees asked Ms. Hunt-Smith to 
see the official bid opening clock but she responded that there is no 
official clock.[3]  Tr. at 75, 140-43.  She told them that she had 
just set her own clock by calling the time on the telephone and that 
at 4:30 p.m. she would lock the door to Room 821 and not accept any 
more proposals.  Tr. at 75-76, 141-42.  When Mr. Greaves asked Ms. 
Hunt-Smith what time her clock had, she glanced to the left of her 
computer (at her telephone clock) and said that it was 3:13 p.m.  Tr. 
at 75-76, 142, 173.  The Caddell representatives did not see her clock 
but Ms. Hunt-Smith stated that she gave them the synchronized time she 
had on her clock.  Tr. at 75-76, 142, 173, 216, 271-72.  Mr. Greaves 
synchronized his watch by setting it to 3:13 p.m. based on the time 
Ms. Hunt-Smith told him.  Tr. at 76, 142-44; Protest at 3.

Mr. Greaves then asked Ms. Hunt-Smith if he and Mr. Gage could use a 
room to finish preparing Caddell's proposal and, after checking, Ms. 
Hunt-Smith led the Caddell employees to the bid opening room, Room 
809, approximately 20 feet down the hall from Room 821.  Tr. at 76, 
144; Protest at 3.  Once in the bid opening room, Mr. Greaves used his 
cellular telephone to make several calls to his company and at about 
4:10 p.m. was told by the company president to call back at 4:15 p.m., 
at which time the final prices would be provided.  Tr. at 83, 146-51; 
Protest at 3.  Because he had a few spare minutes, Mr. Greaves 
returned to Room 821, where he again asked Ms. Hunt-Smith for the 
time.  Tr. at 83, 152-54.  She told him that the time was 4:12 p.m, 
Tr. at 154, which was consistent with the time on Mr. Greaves's watch.  
Protest at 3-4.  Ms. Hunt-Smith testified that when she told Mr. 
Greaves this time she was looking at her telephone clock and that she 
also verified this time with Ms. Senne.  Tr. at 217, 236-37.  Mr. 
Greaves returned to the bid opening room and telephoned the company 
president at 4:20 p.m., who provided the names of subcontractors to be 
used in the proposal and the final prices.  Tr. at 155-57; Protest at 
4.  As indicated by telephone records from Caddell's cellular phone 
carrier, this telephone call was completed at about 4:25 p.m. and the 
Caddell employees proceeded to finish preparing the proposal.[4]  Tr. 
at 157-60.  They kept the doors to this room shut while they did so.  
Tr. at 83-84.

As 4:30 p.m. approached, Ms. Hunt-Smith, Ms. Senne, and two other 
Corps employees, Contract Specialist Lisa Frazier and Procurement 
Technician Janet Lee, were in the reception area of Room 821 
discussing among themselves whether Caddell would get its proposal in 
on time.  Tr. at 218, 240-41, 272-73, 315, 335, 344-45, 354.  Ms. 
Hunt-Smith then sat at her desk, and when she heard the time/date 
stamp click and observed her clock change to 4:29 p.m., decided to 
notify the Caddell employees of the time.  Tr. at 218-19, 355.  She 
left her cubicle, opening the door leading into the hallway and called 
out, "It's 4:29.  Are there any other proposals?"  Tr. at 218-19, 
242-43, 273, 319-20, 335, 355, 399.  This was also witnessed by two 
Harbert employees, who were returning to Room 821 after submitting 
their proposal to see if any other offerors were submitting proposals.  
Tr. at 219, 398-99.  

What happened next is in dispute.  According to the accounts of Ms. 
Hunt-Smith and the other Corps employees, after Ms. Hunt-Smith 
announced that it was 4:29 p.m., she waited in the hallway briefly, 
then proceeded to walk down the hallway, disappearing from the view of 
the other employees in Room 821.  Tr. at 218-19, 273, 319-20, 335, 
355.  Ms. Hunt-Smith claims that she then opened the door to Room 809, 
went in, faced the Caddell employees, and asked them, "Are you going 
to turn in your proposal?" (they answered "Yes") and stated to them, 
"It was 4:29 when I left the door and the clock was still ticking."  
Tr. at 220, 249-251.  The Harbert employees, who were standing in the 
hallway, testified that Ms. Hunt-Smith opened the door to Room 809, 
announced that it was 4:29, shut the door, and walked back to Room 
821.  Tr. at 178-79, 399, 431.  The Caddell employees deny that Ms. 
Hunt-Smith opened the door to Room 809 and came in and warned them of 
the time, Tr. at 443, 446-47, but state that they did hear a voice in 
the hallway shout, "It's 4:29!"  Tr. at 88, 106, 115, 159-60, 176.

During Ms. Hunt-Smith's absence, Ms. Senne observed the time/date 
stamp machine click from 4:29 p.m. to 4:30 p.m., which her clock 
confirmed.  Tr. at 273, 276-77, 310.  Then Ms. Senne, who is 
responsible for locking the door to Room 821 for the day at the 4:30 
p.m. close of daily office hours, considered whether she should do so 
in Ms. Hunt-Smith's absence.  Tr. at 273.  Lisa Frazier, who was in 
Ms. Hunt-Smith's cubicle, observed the time on Ms. Hunt-Smith's clock 
and on her computer read 4:30 p.m., and said out loud that the time 
was 4:30 p.m. and that someone should lock the door.  Tr. at 335-36.  
Since no one appeared to be going to the door she proceeded to lock 
it.  Tr. at 273, 336.  After she locked the door, Ms. Frazier heard 
the time/date stamp clock click 4:31 p.m.  Tr. at 336.  This time 
frame is confirmed by Ms. Senne, who witnessed Ms. Frazier lock the 
door.  Tr. at 273-74.

Meanwhile, the two Harbert employees who were waiting in the hallway 
near Room 821 complained to Ms. Hunt-Smith as she returned that the 
deadline for receipt of proposals had arrived.  Tr. at 220-21, 400-01, 
432.  Ms. Hunt-Smith then returned to Room 821, found the door to the 
room locked, knocked, and was admitted, she believes, by either Ms. 
Frazier or Ms. Senne.  Tr. at 221.  Although it is not clear which 
Corps employee unlocked the door to admit Ms. Hunt-Smith, she recalled 
that either Ms. Senne or Ms. Frazier then said, "Well, you weren't in 
here at 4:30 to lock the door and we waited until 4:31 and we locked 
the door."  Tr. at 221, 244-45.  Ms. Senne observed from her desk that 
the time was 4:31 p.m. when the door was locked and Ms. Hunt-Smith 
returned.  Tr. at 273-74.  Ms. Hunt-Smith then sat at her desk, 
observing that her clock read 4:32 p.m.  Tr. at 221.  Ms. Senne also 
testified that the time/date stamp machine clicked to 4:32 p.m.  Tr. 
at 274.  They then heard and saw the Caddell employees at the door.  
Tr. at 221, 274, 326, 327.  Ms. Hunt-Smith then went to the door and, 
according to her, said through the locked door, "I'm sorry, but you're 
late."  Tr. at 221, 255.  After the Caddell employees went back down 
the hallway Ms. Hunt-Smith went to notify Joseph Theobald, the Chief 
of Contracting for the Louisville District, about the situation.  Tr. 
at 222, 326-27, 372.

The Caddell employees testified that after they heard the voice in the 
hallway announce that it was 4:29, they "scribbled in" the remaining 
three prices on the last copy of the schedule, picked up their 
proposal and "sprinted" to Room 821.
Tr. at 89-90, 159-60.  They noticed the two Harbert employees waiting 
outside Room 821 but did not see any Corps employees in the hallway.  
Tr. at 90-91, 161.  As Mr. Greaves drew close to Room 821, he heard 
the door being locked.  Tr. at 161.  One of the Caddell employees 
tried to push the door open and Messrs. Greaves and Gage observed 
through the glass Ms. Hunt-Smith, with her hands in the air, backing 
away from the locked door.  Tr. at 92, 161-62.  Mr. Greaves looked at 
his watch and saw that the minute hand was not yet on 4:30 p.m. but 
still on 4:29 p.m.  Tr. at 92, 162; Protest at 4-5.  Because the door 
was locked, the Caddell employees were unable to enter the room to 
view Ms. Hunt-Smith's clock or any other Corps time--piece to verify 
the time.  Tr. at 93, 162.

The Caddell employees returned to Room 809 and were joined by Mr. 
Theobald.  Tr. at 163.  Mr. Theobald asked the Caddell employees what 
had happened and they recounted the incident to him.  Id.  Mr. Greaves 
told Mr. Theobald that no more than 30 seconds could have elapsed 
between the time he heard the voice in the hallway shout "It's 4:29" 
and the moment he heard the door lock click.  Tr. at 113, 163.  Mr. 
Greaves also complained about the lack of an official clock.  Tr. at 
163-64.  The Caddell employees requested that Mr. Theobald take their 
proposal, which he did, but Mr. Theobald told them he would treat it 
as late.  Tr. at 164-65, 363.

ANALYSIS

It is an offeror's responsibility to deliver its proposal to the 
proper place at the proper time, and late delivery generally requires 
rejection of the proposal.  The Staubach Co., B-276486, May 19, 1997, 
97-1 CPD  para.  190 at 3.  In determining whether a proposal was submitted 
late, we consider all relevant evidence in the record, including 
statements by parties on behalf of the protester and the agency, to 
ascertain whether a preponderance of the evidence shows that the 
proposal was at the designated location for receipt prior to the time 
set for closing.  Med-National, Inc., B-277430, Sept. 8, 1997, 97-2 
CPD  para.  67 at 3; IPS Group, B-235988, Oct. 6, 1989, 89-2 CPD  para.  327 at 2; 
International Steel Erectors, B-233238, Feb. 13, 1989, 89-1 CPD  para.  146 
at 3.  

A hand-carried proposal that arrives late may be considered if 
improper government action was the paramount cause for the late 
submission, and where consideration of the proposal would not 
compromise the integrity of the competitive procurement process.  
Med-National, Inc., supra, at 3.  Improper government action in this 
context is affirmative action that makes it impossible for the offeror 
to deliver the proposal on time.  Id.  Even in cases where the late 
receipt may have been caused, in part, by erroneous government action, 
a late proposal should not be considered if the offeror significantly 
contributed to the late receipt by not acting reasonably in fulfilling 
its responsibility to deliver a hand-carried proposal to the proper 
place by the proper time.  International Steel Erectors, supra, at 4.  
In our view it is within the agency's discretion to initially 
determine whether or not it may have been the paramount cause of the 
late receipt of a proposal, and our Office will not substitute its 
judgment in this regard, but will review the reasonableness of the 
agency's determination.

We agree with Caddell that the Louisville District has an "odd 
timekeeping procedure" for receipt of proposals on RFPs.  Hearing 
Comments at 17.  However, we disagree with Caddell that the Corps used 
one basis (Ms. Hunt-Smith's clock) to inform Mr. Greaves of the time, 
which he used to synchronize his watch, but used another basis (the 
time/date stamp machine) for purposes of determining when the 4:30 
p.m. deadline for proposal submission had arrived and for locking the 
doors to Room 821.  As described above, the time/date stamp machine 
used to keep the official time and Ms. Hunt-Smith's telephone clock 
were purportedly synchronized to read the same time.  However, even 
if, as the protester asserts, the Corps has failed to demonstrate that 
its synchronization of the clocks was accurate, the record shows that 
the agency's basis for determining Caddell's proposal late was not the 
time/date stamp machine itself, but the clock on Ms. Hunt-Smith's 
desk, the same clock used earlier by Ms. Hunt-Smith to tell Caddell's 
representative, Mr. Greaves, the time, and which he used to 
synchronize his watch.

Specifically, as described above, before venturing into the hallway to 
announce "It's 4:29," Ms. Hunt-Smith observed that her clock read 4:29 
p.m.  While Ms. Hunt-Smith was out in the hallway, Ms. Frazier noticed 
that the time had reached 4:30 p.m. on Ms. Hunt-Smith's clock and that 
the doors to Room 821 should be locked.  In this regard, the record 
shows that this Corps's office standard procedure was to lock the 
doors to the office at the close of business at 4:30 p.m., even when 
proposals were due to be submitted by that time.  Tr. at 243-44, 
277-78, 322, 347.  When Ms. Hunt-Smith returned to her cubicle she 
observed that her clock read 4:32 p.m. before she heard Caddell's 
employees at the door.  Although the record indicates that these times 
were verified by Corps employees on the basis of the time/date stamp 
machine and Ms. Senne's clock, the record also shows that the basis 
for locking the door to Room 821 and concluding that the time set for 
closing had passed was Ms. Hunt-Smith's clock rather than the 
time/date stamp machine itself (although the two time-pieces were 
allegedly synchronized), notwithstanding the latter's status as the 
keeper of the official time.  Since Ms. Hunt-Smith's clock was used as 
the common basis on which Mr. Greaves synchronized his watch and on 
which the Corps locked the door to Room 821 at 4:30 p.m. and gauged 
the time of arrival of Caddell's employees at the door, we find no 
merit to Caddell's objection that a different time-keeping device was 
used by the Corps to advise Caddell of the time than that used to 
determine the closing deadline.

Caddell nonetheless maintains that the Corps failed to provide 
offerors with an official clock in plain view, which could have been 
used to prevent such incidents, despite the fact that the Corps was 
aware that the lack of such a clock had caused similar problems in the 
recent past.  Protest at 14.  While such a clock may be desirable and 
commonly used elsewhere, as claimed by the protester, we are aware of 
no requirement that the Corps have a clock in plain view to determine 
deadline times for receipt of proposals, and the protester has cited 
no supporting authority in this regard.  Rather, in analogous 
situations under advertised procurement procedures, the decisive event 
in determining the time for bid opening is not the ticking of a clock, 
but the agency's reasonable declaration of the start of bid opening 
that demarcates the point in time at which a hand-carried bid will be 
determined either timely or late.  See Nueva Constr. Co., Inc., 
B-270009, Jan. 16, 1996, 96-1 CPD  para.  84 at 4.  Similarly, in negotiated 
procurements, we have held that, unless it is shown to be 
unreasonable, the contracting official's declaration that a 
procurement is closed is determinative.  See Pat Mathis Constr. Co., 
Inc., B-248979, Oct. 9, 1992, 92-2 CPD  para.  236 at 3; Seer Publishing, 
Inc., B-237359, Feb. 12, 1990, 90-1 CPD  para.  181 at 6.

Here, whether or not Ms. Hunt-Smith actually entered Room 809 to warn 
the Caddell employees that the time for submitting proposals was 
almost up, the record shows that when she observed that the time was 
4:29 p.m. by her clock, she decided to warn the Caddell employees 
about the time, got up and opened the door to Room 821, stood in the 
doorway, called out that the time was 4:29 p.m., walked down the 
hallway to further warn Caddell, returned to Room 821, locked the door 
(after initially finding the door locked and being admitted back into 
the room where other employees explained to her that they waited until 
after 4:30 to lock the door), returned to her cubicle, and observed 
that her clock read 4:32 p.m. before hearing the Caddell employees at 
the door.  Accordingly, we cannot conclude that Ms. Hunt-Smith's 
determination that the time for submission of proposals had 
passed--her locking of the door and refusal to admit the Caddell 
employees to the room--was premature or otherwise unreasonable.  The 
protester has not suggested any persuasive reason why Ms. Hunt-Smith 
would announce "It's 4:29" before her clock actually displayed 4:29 
p.m., or why she subsequently would lock the door to Room 821 prior to 
4:30 p.m., especially after warning Caddell about the time, a courtesy 
she was under no obligation to give.

We also find that the preponderance of the evidence does not show that 
Caddell's proposal was at the designated location for receipt prior to 
the time set for closing.  In this regard, Caddell's self-serving 
statement that when Mr. Greaves reached the locked door to Room 821 
his watch read 4:29 p.m. is counterbalanced by the observations of 
several Corps employees, who the record shows were keenly interested 
in whether Caddell would submit its proposal on time, that Ms. 
Hunt-Smith's clock reached 4:30 p.m. before the door was locked and 
that the Caddell employees reached the door to Room 821 at 4:32 p.m.  

Moreover, the record establishes that Mr. Greaves's synchronized his 
watch, which had an analog dial but no second hand, only to the hour 
and minute.[5]  Tr. at 127, 183.  Thus, when Mr. Greaves synchronized 
his watch with the time on Ms. Hunt-Smith's clock, his watch could 
have been off by almost a minute.  For example, such a discrepancy 
could have occurred if the time on Ms. Hunt-Smith's clock was actually 
58 seconds into the minute of 3:13 p.m. and Mr. Greaves set his watch 
to the beginning of that minute.[6]  Since by Caddell's own admission, 
Mr. Greaves watch indicated 4:29 p.m. when he and Mr. Gage reached the 
door of Room 821, Ms. Hunt-Smith's clock could very well have already 
reached 4:30 p.m., making the proposal late, notwithstanding that Mr. 
Greaves's watch still read 4:29 p.m.[7]

While the Caddell employees claim that after they heard the voice in 
the hallway announce "It's 4:29" it took them no longer than 30 
seconds to fill in their last prices and take their proposal to the 
door of Room 821 (and not the 3 minutes that would result in their 
arrival at Room 821 at 4:32 p.m.), Tr. at 163, this does not mean they 
tendered the proposal in a timely manner.  In this regard, Caddell 
does not dispute that when its employees heard the voice in the 
hallway announcing "It's 4:29," that the time on Ms. Hunt-Smith's 
clock had already reached 4:29 p.m.[8]  Given that it obviously took 
Ms. Hunt-Smith some time to leave her office and issue the warning, as 
well as the conceivable difference described above in the 
synchronization between Mr. Greaves's watch and the time used to 
determine the proposal submission deadline, it is certainly possible, 
if not likely, that Ms. Hunt-Smith's clock, from which Mr. Greaves had 
synchronized his watch and which served as the basis for determining 
the deadline for proposal submission, could have reached 4:30 p.m. by 
the time the Caddell employees reached the door to Room 821.  

While we cannot say definitively that Messrs. Greaves and Gage had not 
reached Room 821 prior to 4:30 p.m., at least by Mr. Greaves's watch, 
the preponderance of the evidence shows that Caddell's proposal was 
not at the designated location for receipt prior to the time set for 
closing, and Caddell's proposal was therefore reasonably rejected as 
late.  See Med-National, Inc., supra, at 12; IPS Group, supra, at 3.

The protest is denied.

Comptroller General
of the United States

1. This decision is made under our express option procedures, 4 C.F.R.  sec.  
21.10 (1998).

2. Besides Caddell, Harbert was the only firm that submitted a 
proposal.

3. According to Ms. Hunt-Smith, the Caddell representatives were 
advised that, although there is no official clock, there is an 
official time, which was the time/date stamp, and that the clock on 
her desk is synchronized to the time/date stamp machine.  Tr. at 216, 
232-233.  Caddell disputes that its employees were told that the 
official time was based on the time/date stamp machine or that the 
clock on Ms. Hunt-Smith's desk was synchronized with it.  Tr. at 86, 
173.

4. There is, however, no evidence that the times shown on the 
telephone bill were exactly the same as those on Mr. Greaves's watch 
or on the time-pieces in the Corps's contracting division.

5. None of the time-keeping devices involved in this case--the 
time/date stamp machine, Ms. Senne's and Ms. Hunt-Smith's telephone 
and computer clocks, the telephone time service, and Mr. Greaves's 
watch, provided time displays in seconds--they only indicated the hour 
and the minute. Tr. at 13, 127, 305.

6. We note that, as described above, Mr. Greaves checked the time 
again with Ms. Hunt-Smith and, according to him, the time she gave him 
then was consistent with the time on his watch.  However, Mr. Greaves 
did concede the possibility that his watch could have been off by as 
much as 20 seconds.  Tr. at 202-03.

7. Because seconds may make the difference between the timely or late 
submission of a proposal, it was unreasonable for Caddell not to take 
into account such a narrow margin of error when synchronizing its time 
to the agency's and not to turn in its proposal with sufficient time 
to allow for possible variances in seconds between its time and the 
time used by the agency.  See generally Pat Mathis Constr. Co., Inc., 
supra, at 4 (by allowing itself less than 1 minute to assemble and 
deliver its proposal, protester assumed the risk that any number of 
events might intervene to prevent the timely submission of its 
proposal).

8. Mr. Greaves did not look at his watch when he heard the 
announcement from the hallway because "I guess when I heard 4:29 I 
knew we were cutting it off close."  Tr. at 159-60.