OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
June 7, 1988
|MEMORANDUM TO:||DIRECTORS OF DIRECTORATES
|FROM:||DAVID C. ZEIGLER, Director
Directorate of Administrative Programs
|SUBJECT:||Small Purchase Procedures|
As most of you know, the office of Procurement Services (OPS) has played an increasing role in processing requisitions to purchase orders over the past few months. With the exception of technical equipment, virtually all of our purchase orders are now processed by OPS.
There is attached a DRAFT statement of the rules that must be followed to assure compliance with existing laws and regulations which OPS has provided to us for comments. While the statement is marked DRAFT, it should be realized that the narrative is taken verbatim from the current Federal procurement regulations.
This office has, for a long time, concurred with and forwarded for processing a number of requisitions which simply had the name and address of an individual, a statement of justification, a daily compensation rate and a description of the service to be obtained. Clearly this will no longer suffice. Prospectively, any requisition for services received must include documentation of your efforts to comply with the existing competitive procedures. Unless the documentation demonstrates a bona fide effort to comply with the competitive requirements, the requisition will be returned without action for additional work.
If you have any questions concerning these procedures or the adequacy of your effects to document you competitive search, please feel free to contact Lionel M. Rogers on 523-9641.
(For Procurement Policy, see printed copy)