This letter was sent to Mr. Crandall Watson, Chief, Procurement Policy Division, U.S. Department of Agriculture
Dear Mr. Watson:
The U.S. Chamber of Commerce (Chamber), appreciates the opportunity to comment on the Agriculture Department’s (USDA) proposed amendments to the Agriculture Acquisition Regulation (AGAR), 87 Fed. Reg. 9005 (February 17, 2022). In particular, the Chamber strongly opposes USDA’s proposed new AGAR contract clauses requiring contractors to report labor law violations for themselves as well as all tiers of subcontractors and suppliers, and any measures taken to remedy labor law violations by the contractor and any tier of subcontractor. These provisions are not supported by any authority and USDA has provided no explanation, supporting data, or context to justify them. In addition, they will create significant burdens and False Claims Act exposure for companies bidding on or working on USDA contracts. Accordingly, the Chamber believes these proposed sections must be withdrawn.
A significant portion of Chamber members are federal contractors and subcontractors. The Chamber also represents many state and local chambers of commerce and other associations who, in turn, represent many additional contractors and subcontractors. Many of these contractors work on contracts governed by the AGAR.
The labor law violations sections (Subpart 422.70—Labor Law Violations; section 452.222-70 (Labor Law Violations contract clause); section 452.222-71 (Past Performance...
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