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.
Comment on FR Doc # E8-23139
This is comment on Proposed Rule
The Women-Owned Small Business Federal Contract Assistance Procedures
View Comment
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