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SCA, Part 2


C Culham

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In a recent thread entitled "Avoidance of SCA" I was taken to task for taking a position.   There are those that still want to lament the closing of the thread for inferior reasons in comments found elsewhere in Forum.   

Most specifically in the noted thread the following was posted by @Vern Edwards with specific reference to a post I had made.  Repeated here is Vern's post -

Let's stay focused on the issue: Should COs, acting on their own authority, be proactive in enforcing the SCA by, among other things, interviewing contractor employees without express authorization from DoL? And does a contract subject to the SCA authorize COs to engage in such activities?

Not soon after the thread was closed, just as I finished the following.   In keeping with the "Title" here is what I finished.   I would be interested in reading everyone's view, including that of @Vern Edwardsbut suspect he will deny wanting to read.  As it goes that is okay by me but I wanted to clarify my position for what it is worth and however dumb it might be.

 

Here is how I see it……

Yes to the first question and Yes to the second.

A Contractor is responsible for quality control of all contract requirements, the Government has authority via a contract to do quality assurance (inspection - in process or post completion) of all contract requirements to assure itself, the Government, the work is completed pursuant to the contract requirements.  Should, with regard to quality assurance, the Government find requirements are not met, the Government is given certain authorities within the contract to enforce the contract requirements to obtain contract work that meets the requirements of the contract.

Specific to SCA with regard to quality assurance the overriding statutes, regulations and most specifically a contract do not give sole authority, via third party beneficiary, to the DOL for quality assurance activities.  What is given to DOL, as a third-party beneficiary, pursuant to 52.222-41 is a dual role with regard to quality assurance, and a sole right in some matters of enforcement regarding violations to obtain compliance with contract requirements.

Nowhere in 52.222-41 does it say inspection for quality assurance of SCA is given up to the DOL by the CO.  Further with regard to the language in the clause regarding interviews it does not say that only the DOL has the right to do interviews but provides instead that the contractor shall permit the DOL to do interviews.

As 52.246-4 has been mentioned it provides for the right to CO for inspection for quality assurance of a contract, a right not overridden by 52.222-41, but supplemented with third party beneficiary role to permit inspection activities of the DOL as well.

Further it has been stated that DOL retains the sole enforcement authority pursuant to 52.222-41 with regard to violations.  I have pointed to where this statement is not correct with regard to the “or” found in paragraph (k) of 52.222-41.  My position is supported by the implementing statutes for SCA, 41 USC 352 and 41 USC 6705.

With regard to sole versus dual authority my research has not uncovered case law or specific legal opinion (administrative of otherwise) that the 52.222-41 grants sole authority to DOL.  I have seen legal advice suggesting that the DOL is given a sole right via the contract.   Advice that I have found has provided no supporting case law that the DOL authority is sole, especially when 52.222-41 is read in the full context of a contract.

The statutes, regulations and clauses of a contract do not prevent a CO from doing quality assurance inspections with regard to SCA but rather the statutes, regulations and clauses of a contract support it and at the same time give the DOL a dual, supportive role, in quality assurance, if the contract is subject to SCA and 52,222-41 is in the contract.  With regard to violations and enforcement of SCA should a contractor not be in compliance, the DOL does retain certain enforcement authority but the CO has certain enforcement authorities as well.

 

 

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  • C Culham changed the title to SCA, Part 2
14 hours ago, C Culham said:

As 52.246-4 has been mentioned it provides for the right to CO for inspection for quality assurance of a contract,

Carl, in the earlier thread, I asked you what contract clause gives the contracting officer the right to interview contractor employees.  You responded by citing to FAR 52.246-4(d).  Here is the text of paragraph (d)  " If the Government performs inspections or tests on the premises of the Contractor or a subcontractor, the Contractor shall furnish, and shall require subcontractors to furnish, at no increase in contract price, all reasonable facilities and assistance for the safe and convenient performance of these duties."  I find nothing in that language that gives a contracting officer the right to interview contractor employees.  Please tell us what language in (d) provides a contracting officer the right to interview contractor employees?

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For purposes of the discussion, here's the applicable definition of "inspection" from FAR 2.101:

Quote

Inspection means examining and testing supplies or services (including, when appropriate, raw materials, components, and intermediate assemblies) to determine whether they conform to contract requirements.

Proceed.

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10 hours ago, Retreadfed said:

Carl, in the earlier thread, I asked you what contract clause gives the contracting officer the right to interview contractor employees.  You responded by citing to FAR 52.246-4(d).  Here is the text of paragraph (d)  " If the Government performs inspections or tests on the premises of the Contractor or a subcontractor, the Contractor shall furnish, and shall require subcontractors to furnish, at no increase in contract price, all reasonable facilities and assistance for the safe and convenient performance of these duties."  I find nothing in that language that gives a contracting officer the right to interview contractor employees.  Please tell us what language in (d) provides a contracting officer the right to interview contractor employees?

The clause does not prevent interviews by the government either. Additionally you concentrate on off Government property inspection.  Am I to understand you believe there are different rights under the clause.  If so, how so?

10 hours ago, Don Mansfield said:

For purposes of the discussion, here's the applicable definition of "inspection" from FAR 2.101:

Proceed.

What about the FAR part 37 definition of services?  Am I to understand that you are suggesting that there is no responsibility of the CO to assure quality of a contractors performance of ALL terms and conditions of a contract?  If so is not such a view inconsistent with, by example, CPARS as to what is to be evaluated regarding a contractors performance.

And as stated more than once in this debate not one case, or other binding legal opinion, that supports that only DOL has the right to do interviews pursuant to 52.222-41. 

 

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On 5/29/2021 at 1:24 AM, C Culham said:

The clause does not prevent interviews by the government either. 

That is not the issue.  The issue is what in that clause gives the contracting officer  the right to conduct interviews of contractor employees.  From your answer, I assume that you cannot find any such language.

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Just now, Retreadfed said:

That is not the issue.  The issue is what in that clause gives the contracting officer  the right to conduct interviews of contractor employees.  From your answer, I assume that you cannot find any such language.

Yes it is as the issue is the construct of contract language or in other words privity of contract.   Privity is between the agency awarding the contract, as represented by the CO, and the contractor.  The clause in question 52.222-41 provides third party beneficiary to the DOL to have some rights under the contract.  Pursuant to the clause the contractor is "permit"ing  the DOL to do interviews.  Reference paragraph (i)(4) of 52.222-41.   In granting the permission to DOL I find nothing in the clause where the contractor is obviating the contracting agency (the CO) from the right to do interviews or otherwise conditioning the DOL permission as a sole right.   Or in other words you can not find any language that gives the DOL sole right rather than a permitted right.   This is bolstered by the fact, as I have pointed out, that the CO has a role with regard to violations as noted in the clause and implementing statute.  

As a comparison consider in the construct of contracts awarded per the FAR and delegations of authority with regard to CO to ACO.  Without such delegation the ACO would have no authority to act.  With regard to the issue we are discussing the DOL would have no authority to act without a similar delegation - interviews and sole right in handling disputes - if the contract did not contain the clause.   Delegation is not necessary where the contract provides the third party beneficiary to DOL.  

 

 

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On 5/28/2021 at 10:24 PM, C Culham said:

Am I to understand that you are suggesting that there is no responsibility of the CO to assure quality of a contractors performance of ALL terms and conditions of a contract?

No, I'm not suggesting anything. I just wanted to prevent an overly broad interpretation of "inspection" that would include nontechnical requirements. 

I'll also add the following:

Quote

 

46.000 Scope of part.

This part prescribes policies and procedures to ensure that supplies and services acquired under Government contract conform to the contract’s quality and quantity requirements. Included are inspection, acceptance, warranty, and other measures associated with quality requirements.

 

Quote

46.101 Definitions

Contract quality requirements means the technical requirements in the contract relating to the quality of the product or service and those contract clauses prescribing inspection, and other quality controls incumbent on the contractor, to assure that the product or service conforms to the contractual requirements.

Government contract quality assurance means the various functions, including inspection, performed by the Government to determine whether a contractor has fulfilled the contract obligations pertaining to quality and quantity.

 

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@C Culham,

How would the interviews not be a "collection of information" as defined by 5 CFR § 1320.3(c)?

Quote

 

Collection of information means, except as provided in §1320.4, the obtaining, causing to be obtained, soliciting, or requiring the disclosure to an agency, third parties or the public of information by or for an agency by means of identical questions posed to, or identical reporting, recordkeeping, or disclosure requirements imposed on, ten or more persons, whether such collection of information is mandatory, voluntary, or required to obtain or retain a benefit. “Collection of information” includes any requirement or request for persons to obtain, maintain, retain, report, or publicly disclose information. As used in this Part, “collection of information” refers to the act of collecting or disclosing information, to the information to be collected or disclosed, to a plan and/or an instrument calling for the collection or disclosure of information, or any of these, as appropriate.

(1) A “collection of information” may be in any form or format, including the use of report forms; application forms; schedules; questionnaires; surveys; reporting or recordkeeping requirements; contracts; agreements; policy statements; plans; rules or regulations; planning requirements; circulars; directives; instructions; bulletins; requests for proposal or other procurement requirements; interview guides; oral communications; posting, notification, labeling, or similar disclosure requirements; telegraphic or telephonic requests; automated, electronic, mechanical, or other technological collection techniques; standard questionnaires used to monitor compliance with agency requirements; or any other techniques or technological methods used to monitor compliance with agency requirements. A “collection of information” may implicitly or explicitly include related collection of information requirements.

(2) Requirements by an agency for a person to obtain or compile information for the purpose of disclosure to members of the public or the public at large, through posting, notification, labeling or similar disclosure requirements constitute the “collection of information” whenever the same requirement to obtain or compile information would be a “collection of information” if the information were directly provided to the agency. The public disclosure of information originally supplied by the Federal government to the recipient for the purpose of disclosure to the public is not included within this definition.

(3) “Collection of information” includes questions posed to agencies, instrumentalities, or employees of the United States, if the results are to be used for general statistical purposes, that is, if the results are to be used for statistical compilations of general public interest, including compilations showing the status or implementation of Federal activities and programs.

(4) As used in paragraph (c) of this section, “ten or more persons” refers to the persons to whom a collection of information is addressed by the agency within any 12-month period, and to any independent entities to which the initial addressee may reasonably be expected to transmit the collection of information during that period, including independent State, territorial, tribal or local entities and separately incorporated subsidiaries or affiliates. For the purposes of this definition of “ten or more persons,” “persons” does not include employees of the respondent acting within the scope of their employment, contractors engaged by a respondent for the purpose of complying with the collection of information, or current employees of the Federal government (including military reservists and members of the National Guard while on active duty) when acting within the scope of their employment, but it does include retired and other former Federal employees.

(i) Any recordkeeping, reporting, or disclosure requirement contained in a rule of general applicability is deemed to involve ten or more persons.

(ii) Any collection of information addressed to all or a substantial majority of an industry is presumed to involve ten or more persons.

 

 

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4 minutes ago, Don Mansfield said:

service conforms to the contractual requirements.

With regard to 46.101 should not the above quote be highlighted as well?  Considering that the service is the "time and effort" of a contractor does not the time need to conform to the requirements of SCA? 

Your position has inconsistency when on one hand you do not believe the CO should not expend effort with regard to conformance of SCA but believe the DOL should.    The government does want and does expend effort to determine assurance that the contractor is complying with SCA and  both the CO and the DOL have the onus to expend that effort.

4 minutes ago, Don Mansfield said:

5 CFR § 1320.3(c)

Okay.....yet I find this point lacks consistency as well.   If the CO can not ask then how can the DOL?   In the context of the quote are not DOL and CO  "agency" and possibly specific to DOL per a contract "third party"?   So if it applies it applies to both? 

I also do not think that the reference is applicable as the implementing statues of SCA grant authority for the gathering of information with regard to possible violations of SCA.   Or, stated another way I do not think that bringing  5 CFR 1320.3(c) to the table by a contractor would bar the government from obtaining information from a contractor with regard to a potential violation of SCA.   In a quick read 5 CFR 1304.4 seems to support my thought. 

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Carl, you seem to be changing your argument.  First, you said that the inspection of services clause gave the contracting officer the authority to interview contractor employees.  Now you are saying it is 52.222-41(i)(4).  However, (i)(4) specifically deals with DoL's ability to interview contractor employees.  Further, (i)(4) is not a creature of the FAR, but a FAR compliance with DoL regulations promulgated to implement the SCA.  Specifically, see 29 CFR 4.6(g) which requires the language found in (i)(4) to be inserted in contracts subject to the SCA.

Going back further to source documents, 41 U.S.C. 6707(a),addressing enforcement of the SCA, states "Sections 6506 and 6507 of this title govern the Secretary’s authority to enforce this chapter, including the Secretary’s authority to prescribe regulations, issue orders, hold hearings, make decisions based on findings of fact, and take other appropriate action under this chapter."  In turn, 41 U.S.C. 6506(b) asserts that "The Secretary may make, amend, and rescind regulations as necessary to carry out this chapter."  41 U.S.C. 6506(e) then provides that "The Secretary, or an authorized representative of the Secretary, may make investigations and findings as provided in this chapter and may, in any part of the United States, prosecute an inquiry necessary to carry out this chapter."   Thus, under this statute, the Secretary can delegate authority to conduct investigations into possible violations of the SCA.  However, without a delegation of authority, the sole power to conduct investigations of possible violations of the SCA rests with the Secretary.  

Putting all of this together, we see that 52.222-41(i)(4) is nothing more than a tool required by regulations issued by the Secretary to carry out his enforcement powers under 41 U.S.C. 6506.  I don't see anything in the foregoing that would indicate that a contracting officer can usurp the power of the Secretary to conduct interviews of contractor personnel without a specific delegation of authority from the Secretary.

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Carl Culham simply does not know what he is talking about.

Some of the things he said in the closed thread and in this continuation are so wrong that it would take an article of law review length to address them all. For example, his the notion that the Department of Labor is a "third party beneficiary" is absurd. If there are any third-party beneficiaries under an SCA-covered government contract they would be the contractor's covered employees.

2 hours ago, C Culham said:

The clause in question 52.222-41 provides third party beneficiary to the DOL to have some rights under the contract. 

He clearly does not know what he's writing about. He is immune to evidence and argument and simply insists, and with each post he wanders further down the nonsense path.

Carl was apparently traumatized by his experience with the Forest Service (USFS) when it and the DOL were criticized by Congress for not looking out for the foreign workers. The trauma has spun him off to an unorthodox, extreme, and unwarranted interpretation of FAR Subpart 22.10, FAR 52.222-41 and FAR 52.246-4.

His experience was unusual because of the location of the worksite, and the deal worked out between the USFS and the DOL departed from standard governmentwide practice. The DOL authorized USFS personnel, pursuant to 29 CFR Part 4, to conduct interviews with certain contractor employees because they were working in remote forests. That is confirmed by the text of the hearings that he referred us to in the prior thread.

Everyone is entitled to an opinion. I would not be bothered if Carl said that COs should take an interest in a contractor's SCA compliance, promptly notify the DOL about any complaints, and comply with its instructions, but he took an extreme position in the prior thread on May 16, at 5:03 PM when responding to ji20874, who said that the DOL is responsible for SCA enforcement and that was okay with him:

Quote

 

Knowledge of a gross injustice, possible fraud, statute violation, you name it and rather than contact the Inspector General or even the DOL, an individual involved closely in government work just casts off the matter as oh well its the geographical area, employees unwilling and government officials who close a minds eye.   

I guess in the scheme of things none of us have responsibilities so one might as well follow a suggestion made in another thread and throw out all contracting statutes and  rather than re-write them simply have none because everybody is "okay with that".

 

Carl has been wrong in all his substantive points, as several persons have pointed out. He ignores that fact that FAR Subpart 22.10 and 52.222-41 must be read in conjunction with 29 CFR Part 4. He ignores long-standing and widely-accepted SCA practice. His invocation of the guiding principles to interpret a contract clause has been refuted by the Civilian Board of Contract Appeals, as cited in the prior thread. His interpretation of the Inspection clause, FAR 52.246-4, is inconsistent with FAR Part 46, which prescribes the clauses, and the plain language of the clause, and is unsupported by anything other than his say-so.

I see nothing wrong with an argument that COs should be interested in a contractor's SCA compliance, but Carl is wrong to suggest that untrained people should go out and conduct interviews of contractor employees without DOL authorization, if for no other reason than such interviews by untrained contract specialists might squirrel an ongoing or future DOL investigation. According to the congressional hearings to which he referred us, the USFS personnel who conducted interviews in the forests were given special training by the DOL.  Nothing in FAR Subpart 22.10, FAR 52.222-41, or 29 CFR Part 4 justify any such course of action, and "inspection" pursuant to FAR 52.246-4 does not encompass such an activity or give a contracting officer any contractual right to do so.

I respect Carl on many contracting matters, but not on this. I will not give him or this thread another moment of my attention.

A thread like this should not be on the Wifcon Beginners page, if on any Wifcon page at all.

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45 minutes ago, Retreadfed said:

Carl, you seem to be changing your argument.

No sir I have not.  I still believe authority exists within the inspection clause for due diligence of of the "time and effort" of a contractor.  I provided a scenerio in the previous thread that demonstrates such when I responded to another.  

 

49 minutes ago, Retreadfed said:

However, (i)(4) specifically deals with DoL's ability to interview contractor employees. 

From you view maybe but the wording actually deal with the contractor agreeing to "permit" DOL to do interviews.

50 minutes ago, Retreadfed said:

Further, (i)(4) is not a creature of the FAR,

So your assertion is that a statute and a CFR of another agency automatically applies to a contract and does not need to be the FAR?  I

As noted we it see it different and so be it.   Noted several times how you see it is not confirmed in case law or other specific legal opinion.  I understand that mine is not as well and so ends the dilemma until there is case law. 

1 hour ago, Retreadfed said:

Thus, under this statute, the Secretary can delegate authority to conduct investigations into possible violations of the SCA.  However, without a delegation of authority, the sole power to conduct investigations of possible violations of the SCA rests with the Secretary.  

As I have pointed out both the statute and the 52.222-41 clause with a specifically positioned "or" address this.  Its not a delegation it is statutory language that says - 

"Enforcement of section

In accordance with regulations prescribed pursuant to section 353 of this title, the Federal agency head or the Secretary is hereby authorized to carry out the provisions of this section."

The statute is not DOL's wording or delegation it is that of the Congress and this statement of the statute gives direction to the DOL that their regulations are to give such authority to the agency head.

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Sorry - Late to the party.

A few questions outside of the extensive background to the OP.

1. Why would a CO want to take on the responsibility of the DOL?

2. If so, why have the DOL? 

3. Wouldn't employees file complaints if not paid what they are required to be paid (with DOL)?

4. Isn't this already addressed with the contractor submitting a quote/offer for evaluation (compliance with the requirements of the SOL and in turn the contract's when signed/accepted)? 

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42 minutes ago, Vern Edwards said:

I will not give him or this thread another moment of my attention.

I believe Vern has said this because in the spirit of discussions found throughout Forum he is a valued resource in finding great information, especially case law or other defining legal opinion, that helps in supporting or not supporting a premise made.  In this most particular case of 52.222-41 Vern has been unable to provide such information.   Rather he provides statements like "Carl Culham simply does not know what he is talking about."  That is his opinion and I have mine and that is it, nothing more with the exception that he depends on the bully pulpit to promote his opinion and I relegated mine to the statutes, regulations, and case law (absence of in this case) to address his challenge  "Lets stay focused...".  You see he wants to make it about me rather than providing the references he needs to make it about a interpretation of contract.

I do agree the thread could be moved, no problem there, but disagree that as proposed in other threads this debate on what a clause does or does not allow is exactly what WIFCON is all about.  

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This has been a spirited discussion.  For me, my thought is unchanged.  I will treat Davis-Bacon contracts differently than Service Contract Act contracts. 

For the former, I will require payroll submissions and conduct employee interviews. 

For the latter, I won't require payroll submissions or conduct employee interviews.  The exception would be if I returned to an agency covered by the Migrant and Seasonal Workers Agricultural Protection Act (MSPA) and that agency had an arrangement with DOL to perform some DOL duties.

In either case, I'll report anything to DOL that should be reported, and will provide assistance as DOL requires.

Other practitioners will have to make their own decisions.

SInce this is the beginner's forum, I think we will better serve our readers by helping them understand that Davis-Bacon Act and Service Contract Act contracts are very different, and that contracting officers have very different responsibilities for those.  I am uncomfortable with trying to treat these similarly.

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3 hours ago, Constricting Officer said:

Sorry - Late to the party.

1. As provided I do not think the responsibilities of the DOL are  they are the responsibilities of the CO as well. 

2. Could that question not be asked o other "boiler plate" clauses in the contract as well.   From discussion past why have anyone paying attention or even have a clause that says a contractor is to comply with Federal, state and local laws.   About covers it so no need for any monitoring for quality assurance with regard to the socio-economic clauses of a contract. 

3.  No.   Examples exist and even in the previous thread it was implied that employees do not complain at the risk of adverse action by an employer.

4.  Do not quite get your question.  The contractor agrees to compliance but whether compliance happens or not is the root to the discussion or in other words how do you know if a contractor is complying or not.

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2 hours ago, ji20874 said:

This has been a spirited discussion. 

No doubt about it.   I too am fine leaving it to those to make their own decision.  I hope I have provided information for thought.

2 hours ago, ji20874 said:

I'll report anything to DOL that should be reported

What would you report? 

Without inquiry does that mean one would just wait for information on employee mistreatment and/or contractor noncompliance regarding SCA? From who?   How does that information get to a CO in a way that suggests referral to the DOL to encourage a full investigation/review? 

 We all know that there are contractors that do not comply with SCA so do you just request DOL do interviews of all contracts, or wait for the few of the many to get caught when DOL finally decides to review a specific contract on their own, when an employee complains, when a union complains or the many by chance happenings that cause a CO concern.   

With sincere honesty I have provided an approach that helps assure contractors comply with SCA.   In offering my approach I have been told many things that in my view has amounted to "Well we have always done it that way" without a concrete representation and reference as to why.   Is my approach right or wrong remains to be seen and I would gladly reconsider my position should someone produce reference rather than a interpretation that shows a CO is acting out of their scope of authority or that of a contract that contains 52.222-41 to ask for information regarding a contractors compliance with SCA, especially that interviews by the CO are prohibited.   

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15 hours ago, C Culham said:

1. As provided I do not think the responsibilities of the DOL are  they are the responsibilities of the CO as well.

"The U.S. Department of Labor's Wage and Hour Division (WHD) is responsible for administering and enforcing some of the nation's most important worker protection laws. WHD is committed to ensuring that workers in this country are paid properly and for all the hours they work, regardless of immigration status." - How to File a Complaint | U.S. Department of Labor (dol.gov)

15 hours ago, C Culham said:

2. Could that question not be asked o other "boiler plate" clauses in the contract as well.   From discussion past why have anyone paying attention or even have a clause that says a contractor is to comply with Federal, state and local laws.   About covers it so no need for any monitoring for quality assurance with regard to the socio-economic clauses of a contract. 

Here's one boiler plate clause:

"52.223-18 Encouraging Contractor Policies to Ban Text Messaging While Driving."

Doesn't mean we "left-seat-right-seat" with their drivers to confirm once a week.

15 hours ago, C Culham said:

No.   Examples exist and even in the previous thread it was implied that employees do not complain at the risk of adverse action by an employer.

That may very well be the case, but that is on the employee. 

15 hours ago, C Culham said:

4.  Do not quite get your question.  The contractor agrees to compliance but whether compliance happens or not is the root to the discussion or in other words how do you know if a contractor is complying or not.

Murder, theft, arson and driving while under the influence are all illegal in this country. We basically agree to those terms when we're born, but the police don't go around to every citizen each morning and ask them if they complied with the law. 

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20 hours ago, C Culham said:

"Enforcement of section

In accordance with regulations prescribed pursuant to section 353 of this title, the Federal agency head or the Secretary is hereby authorized to carry out the provisions of this section."

What is this from?

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3 hours ago, Constricting Officer said:

Everyone in DC has a government purchased and issued cell phone. Sure there is something those contracts that says they can't be made in a China sweat shops. News flash - they are!

So there you go!  

To your last two posts feel free to be signatory as a CO and not worry about assurance of ALL  contract requirements.  Quite permissible as nobody else worries.

 

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1 hour ago, C Culham said:

To your last two posts feel free to be signatory as a CO and not worry about assurance of ALL  contract requirements.  Quite permissible as nobody else worries.

There it is. You sign and administer your contracts as you see fit. I shall do the same. Easy day. 

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