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(6) If required, did the Grantee use in-plant inspectors during the manufacturing<br />

process?<br />

(7) Does the Grantee have a description of the manufacturing activities taking place<br />

during the final assembly of the vehicles and, for vehicles that were partially<br />

manufactured outside the United States, did the final assembly meet <strong>FTA</strong><br />

requirements?<br />

5.5.4 In the second case the PMOC or <strong>FTA</strong> project manager has the triennial report available to<br />

establish how the Grantee has handled Buy America issues in the past and provides some<br />

guidance for matters that require special attention.<br />

6.0 SCOPE OF WORK<br />

In addition to the reviews of submittals indicated above, as part of its monthly report, the PMOC<br />

shall include recommendations for <strong>FTA</strong> to take corrective action with the Grantee. Before<br />

making such a report, the PMOC shall discuss possible corrective action with the Grantee, and<br />

report the intended corrective action concurrently.<br />

6.1 Discrepancy Type 1: Grantee/Sponsor is deficient and did not have Buy America<br />

requirements in its procurement contracts for iron, steel, or manufactured products and/or<br />

does not have an <strong>FTA</strong> approved waiver.<br />

6.1.1 Corrective Action: PMOC must advise Grantee to revise its procurement procedures to<br />

include the Buy America provisions, including the requirement to obtain vendor signed<br />

Buy America certifications.<br />

6.1.2 Corrective Action: PMOC shall direct Grantee/Sponsor to submit revised purchasing<br />

procedures to the <strong>FTA</strong>.<br />

6.2 Discrepancy Type 2: Grantee/Sponsor is deficient and did not conduct all of the required<br />

review for its rolling stock procurement. Grantee/Sponsor does not have all of the<br />

required certifications in its files.<br />

6.2.1 Corrective Action: The PMOC should advise the Grantee/Sponsor to locate and sign all<br />

missing but required certifications.<br />

6.2.2 Corrective Action: If the certifications cannot be located, the PMOC should direct<br />

Grantee/Sponsor conduct “after-the-fact” Pre-Award or Post-Delivery audits to verify<br />

that the procurement complies with domestic content and final assembly requirements.<br />

6.3 Discrepancy Type 3: Grantee/Sponsor is deficient and has placed vehicles into revenue<br />

service, before completing Pre-Award and/or Post-Delivery Audits.<br />

6.3.1 Corrective Action: The PMOC should direct the Grantee/Sponsor to provide the <strong>FTA</strong><br />

with an explanation for how/why vehicles were placed in service before completing the<br />

Pre-Award and Post-Delivery Audits.<br />

OP26A Buy America Review<br />

Revision 0, June 2008<br />

Page 11 of 14

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