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B-230762 1 (1988-05-18)

handle is hein.gao/gaobadncc0001 and id is 1 raw text is: The Comptroller General of the United States Washington, D.C. 20548 I T Decision Matterof. The Veterans Administration--Request for Advance Decision File: B-230762 Date: May 18, 1988 DIGEST For purposes of the Buy American Act, structural steel detailing is not a component of fabricated steel because the detailing is not an article, material or supply that is directly and physically incorporated into the final fabricated steel. DECISION The Veterans Administration (VA) requests our Office's opinion concerning whether, in applying the Buy American Act, structural steel detailing should be considered a component of fabricated steel. The Buy American Act requires that only domestic construction material be used in public buildings or works 'in the United States unless such material is not reasonably available in sufficient quantities of satisfactory quality, or its use is impracticable or would unreasonably increase the project's cost. Federal Acquisition Regulation (FAR) 25.202 (FAC 84-12). Domestic construction material is unmanufactured material mined or produced in the United States, or material manufactured in the United States if the cost of its components mined, produced or manufactured in the United States exceeds 50 percent of the cost of all its components; components are articles, materials or supplies incorporated directly into construction material. FAR q 25.201. To determine if a construction material is domestic only the material itself and its components are considered. Id. According to the VA, structural steel detailing is an engineering function in which the detailer, under subcontract to the structural steel fabricator, prepares shop drawings that are used to fabricate the steel. The VA's position is that because the detailing involves only labor, it should not be considered a component of the final fabricated steel. The opinion of at least one domestic steel detailer, however, is that the shop drawings that are

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