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UNAUTHORIZED PURCHASING OF BOTTLED WATER AND ICE WITH MILITARY PERSONNEL MARINE CORPS (MPMC)/1105 SUBSISTENCE IN KIND (SIK) APPROPRIATION

Date Signed: 4/16/2018
MARADMINS Number: 218/18

R 161555Z APR 18
MARADMIN 218/18
MSGID/GENADMIN/CMC WASHINGTON DC L LF//
SUBJ/UNAUTHORIZED PURCHASING OF BOTTLED WATER AND ICE WITH MILITARY PERSONNEL MARINE CORPS (MPMC)/1105 SUBSISTENCE IN KIND (SIK) APPROPRIATION//
REF/A/DOC/MCO 10110.14N//
REF/B/DOC/MCRP 3-40G.1//
REF/C/DOC/DON FMPM//
REF/D/DOC/DOD 7000.14-R//
REF/E/DOC/NAVMC 2664 REV 1.0//
REF/F/DOC/GAO RULING B-318588//
REF/G/DOC/40 CFR 141//
NARR/REF (A) IS THE MARINE CORPS ORDER ON THE FOOD SERVICE AND SUBSISTENCE PROGRAM. REF (B) IS THE MARINE CORPS FIELD FEEDING PROGRAM. REF (C) IS THE DEPARTMENT OF THE NAVY FINANCIAL MANAGEMENT POLICY MANUAL. REF (D) IS THE DEPARTMENT OF DEFENSE FINANCIAL MANAGEMENT REGULATION VOLUME 10. REF (E) IS THE MARINE CORPS FINANCIAL GUIDEBOOK FOR COMMANDERS. REF (F) IS A GOVERNMENT ACCOUNTABILITY OFFICE (GAO) RULING ON THE PURCHASE OF BOTTLED WATER. REF (G) IS THE NATIONAL PRIMARY DRINKING WATER REGULATIONS//
POC/C. GIRARD/CIV/MCICOM G-4/TEL: (703)604-4511/EMAIL: CHARLES.GIRARD@USMC.MIL//
POC/T.A. JOHNSON/MAJOR/LPC/TEL: (571)256-7127/EMAIL: TROY.A.JOHNSON1@USMC.MIL//
POC/S. RITTER/RFC–P (AND) R/TEL: (703)614-0710/EMAIL: SHARI.RITTER@USMC.MIL//
RMKS/1.  Purpose.  To amplify guidance for commands or units purchasing bottled water and ice.
2.  Discussion.  Per ref (a), nonfood items (i.e., napkins, paper products, charcoal and charcoal lighter, ice, bottled water, etc.) will be procured with command Operational and Maintenance Marine Corps (O AND MMC) funds.  Procurement of these items with MPMC/1105 SIK appropriation is not authorized.
3.  Per ref (b), SIK funding is used to procure subsistence (food) items from the Defense Logistics Agency Troop Support (DLA TS) Prime Vendor (PV) or other contracted commercially approved sources of supply.  Bottled water and ice are not considered food items and cannot be requisitioned using MPMC/1105 SIK funds.
4.  DLA TS PV’s carry bottled water which may be procured through the Subsistence Total Order and Receipt Electronic System (STORES) account linked to using units O AND MMC (1106) funds if the conditions outlined in ref (c) and (d) are satisfied.  The DLA TS website has guidance on how to request a STORES account.  (https:(slash)(slash)www.stores.dla.mil/stores_web)
5.  Per ref (c), the GAO’s long standing rule is that bottled water is a personal expense unless a showing of necessity can be made, i.e., the agency can determine that potable water is not available.  For additional information, ref (f) is a GAO ruling on the purchase of bottled water.
6.  As a necessary expense of a traditional ceremony, appropriated OMMC funds may be used to purchase bottled water when it is determined to be a necessary expense of a traditional ceremony due to health and safety concerns.  When applying the necessary expense rule, an expenditure can be justified after meeting a three-part test:
6.A.  The expenditure must bear a logical relationship to the appropriation sought to be charged.
6.B.  The expenditure must not be prohibited by law.
6.C.  The expenditure must not be otherwise provided for, that is, it must not be an item that falls within the scope of some other appropriation or statutory funding scheme.  This determination must be made on a case-by-case basis taking into consideration the particular facts and circumstances of each traditional ceremony.  Factors to be considered would include, but not be limited to, the availability of water, the time of day, the weather, the geographic location, and the scale of the event.
7.  In absence of statutory authority, appropriated funds may not be used for stockpiling bottled water for an anticipated event, e.g., hurricane.
8.  Per ref (d), special drinking water may be purchased with appropriated (O AND MMC) funds in situations where water supply systems providing service to DOD organizations do not meet the standards prescribed in ref (g).  Special drinking water may be purchased with appropriated funds only when it is necessary from the government's standpoint.  The claim for reimbursement requires a statement attesting the drinking water is non-potable along with a public announcement or a copy of the water testing results.  Some examples are:
8.A.  The public water is unsafe for human consumption.
8.B.  There is an emergency failure of the water source on the installation.
8.C.  There is a temporary facility with no drinking water available within a reasonable distance.
8.D.  There is no water fit for drinking purposes available without cost or at a lower cost to the government.
9.  Release authorized by MajGen Vincent A. Coglianese Assistant Deputy Commandant Installations and Logistics (Facilities).//