Friday, June 10, 2011

NCJC Position on First Source Amendment

A Law With Teeth - It is also of merit to note that when legislators intend for a law to be enforced, they include both the specific regulation, substantive penalties for infractions, and the funds to implement all elements of the law and the regulations.  Let  us hope that this will be the case here.

Here's What's Needed - One, there should be a First Source Officer who is a single point of contact for all questions and documentation.  That person should be personally liable for the accuracy and validity of all data supplied in reference to the law.  This is not without precedent.  The GMP’s (good manufacturing practices) regulations call for personal responsibility AND criminal penalties for failure to adhere.

Visual Display by Prime Contractor - We also feel strongly about visible displays.  I suggest that a graphic sign equal in size and visibility to the contractor and prime be co located in a prominent place visible to the public. 

The sign should display:  The name of the prime contractor and major sub contractors on the sight.  The sign also should contain t he following:  1) The name of the First Source Officer along with contact information.  2) The number of all trades and laborers working on the site.  3) The number of trades and laborers who live in DC.  3) The percentages of labor hours required by First Source and the average percentages of hours worked by category over the previous reporting perion (month, quarter, etc)  At the bottom.  These should be adjacent to each other for easy comparison.  Finally, there should be  a tally board and back up documentation should be maintained by the First Source Officer at his desk on the site.  This board should be kept updated (with penalties for failing to do so) and available on demand by any person or organization with standing.

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