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  • Question

    Does the Construction Micro Purchase Threshold of $2,000 only apply to the purchase of materials if a service/labor rate is involved? Does the limit apply to each material item purchased individually, or only for the total amount of all materials per project?


    Answer

    What your question is asking is do the Construction Wage Rates (Davis Bacon) apply to your acquisitions.  You can find the requirements for this under FAR subpart 22.4.  The scope of this subpart states that it applies to construction, alteration, or repair.  The definition of “Construction, alteration, or repair” can be found in FAR 22.401 it states, “…means all types of work done by laborers and mechanics employed by the construction contractor or construction subcontractor on a particular building or work at the site…”
     
    The fact that you are not hiring laborers and mechanics or a construction contractor, then the Construction wage rates would not apply to your contract. 
     
    So what type of contract do you have?  I offer you the following 3 illustrations to provide a better understanding:
     
    1.  Carpet purchased and installed in a single room – (Labor is incident to the cost of the carpet - like Home Depot $5 sq. yd. installed) – Answer: This is a Commercial Item Supply Contract – no wage rates
     
    2.  Carpet purchased as part of a building renovation project – Answer: Construction item of work and labor paid - Construction Wage Requirements Statute Wages.
     
    3.  Extra role of carpet laying around Government furnished, contracted labor to install (no other work involved)  - Answer: This is a Service Contract and  labor paid - Service Contract Labor Standards statute
     
    Your situation would fall under scenario 1.

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