Comment on FR Doc # E8-23139

Document ID: SBA-2008-0006-0002
Document Type: Public Submission
Agency: Small Business Administration
Received Date: October 02 2008, at 02:45 PM Eastern Daylight Time
Date Posted: October 24 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: October 1 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: October 31 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8073387a
View Document:  View as format xml

View Comment

Before this proposed rule I did not care what NAICS code we were classified under or how accurate it was.I just thought of it as an organizational tool with little ramifications regarding the opportunities available to my firm. Now that the NAICS code has such huge ramifications regarding government contract opportunities for a WOSB like mine my interest has piqued. I believe the method of calculations used and the data involved infringe on my constitutional right to fair and equal treatment under the law. The basis of under/over representation in an industry is inherently flawed in my case because my NAICS classification of 333999 - All Other Miscellaneous General Purpose Machinery Manufacturing is technically (but very importantly) in no way indicative of my industry, nor is it meant to be, this is a fact. This NAICS code does not represent an industry but merely represents a failure on the governments part to classify the filtration industry. The only significant characteristic that the filtration industry shares with the other industries plopped into this group is the purely government created characteristic of not being properly classified. It is probably no coincidence that a significant portion of the filtration industry exists solely through government contracting. The extent of this truth is so overwhelming that the neutrality of placing the filtration industry into the "All Other" category must be questioned. The "All Other" category will become a tool to manipulate the availability of WOSB relief for industries with similar characteristics. You have a duty to try harder at classifying industries in NAICS 333999.

Related Comments

    View All
Total: 36
Comment on FR Doc # E8-23139
Public Submission    Posted: 10/24/2008     ID: SBA-2008-0006-0002

Oct 31,2008 11:59 PM ET
Comment on FR Doc # E8-23139
Public Submission    Posted: 10/24/2008     ID: SBA-2008-0006-0003

Oct 31,2008 11:59 PM ET
Comment on FR Doc # E8-23139
Public Submission    Posted: 10/24/2008     ID: SBA-2008-0006-0004

Oct 31,2008 11:59 PM ET
Comment on FR Doc # E8-23139
Public Submission    Posted: 10/24/2008     ID: SBA-2008-0006-0005

Oct 31,2008 11:59 PM ET
Comment on FR Doc # E8-23139
Public Submission    Posted: 10/31/2008     ID: SBA-2008-0006-0008

Oct 31,2008 11:59 PM ET