FAR 25.1103(e) says to include the provision 52.225-25, Prohibition on Engaging in Sanctioned Activities Relating to Iran--Certification, in "each solicitation for the acquisition of PRODUCTS or SERVICES [emphases added]".
The text "products or services" could be interpreted to mean "supplies and services only" (not construction).
The FAR matrix indicates that 52.225-25 is applicable to ALL solicitations, including those for construction.
Cecilia Davis stated during a telephone conversation that the intended meaning of 25.1103(e) is that 52.225-25 is applicable to ALL solicitations, not only to those for supplies and services.
To preclude 25.1103(e) from being misinterpreted as described above, I recommend rewording 25.1103(e) to read somewhat as follows:
"The contracting officer shall include the provision at 52.225-25, Prohibition on Engaging in Sanctioned Activities Relating to Iran--Certification, in ALL [emphasis added] solicitations."
That recommended wording will make it clear that 52.225-25 should be included in ALL solicitations, including those for construction. That recommended wording will preclude the possibility of somebody misinterpreting the prescription for use of 52.225-25 to mean that 52.225-25 is to be used only in solicitations for supplies and services.
Comment on FR Doc # 2010-24165
This is comment on Rule
Federal Acquisition Regulations: FAR Case 2010-012; Certification Requirement and Procurement Prohibition Relating to Iran Sanctions
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