GSA utilizes Special Item Numbers (SINs) to categorize the product or service offerings contractors can have awarded on the Multiple Award Schedule (MAS). Many SINs require contractors’ or offerors’ services to meet specific standards or regulations to have the SIN awarded. A popular SIN that limits the types of services vendors can provide is the Engineering Services SIN or SIN 541330ENG. For example, traditional architect-engineer (A-E) services are not allowed to be sold through this SIN or any other SIN in general. However, the Engineering SIN is not the only SIN that limits engineering firms in their service offerings; the Environmental Consulting Services SIN also requires contractors or offerors looking to add this SIN to meet a few requirements.
We have previously addressed the requirements necessary to have the Engineering SIN awarded. In this blog, we will focus on the Environmental Consulting SIN and discuss the SIN’s description, which services are and are not procured through this SIN, and similar environmental service-based SINs that also have special requirements.
The Environmental Consulting SIN or SIN 541620 falls within the Professional Services Category and the Environmental Services Subcategory. About 575 contractors have this SIN awarded, and it is common for contractors to have both the Environmental Consulting SIN and the Engineering SIN awarded. GSA provides the following description of services typically procured under the Environmental Consulting SIN:
“541620 Services include providing advice and assistance to businesses and other organizations on environmental issues, such as the control of environmental contamination from pollutants, toxic substances, and hazardous materials; endangered species, wetland, watershed, and other natural resource management plans; Archeological and/or cultural resource management plans. This includes identifying problems (e.g., inspect buildings for hazardous materials), measure and evaluate risks, and recommend solutions. Multi-disciplined staff of scientists, engineers, and other technicians with expertise in areas, such as air and water quality, asbestos contamination, remediation, ecological restoration, and environmental law such as Planning and Documentation Services for the development, planning, facilitation, coordination, and documentation of and/or for environmental initiatives.”
Contractors can also be categorized under the Environmental Consulting SIN’s subgroups depending on your company’s services: Archaeology and Cultural Resource Services, Environmental Management Systems (EMS), and National Environmental Policy Act (NEPA) Related Services. These subgroups are used by federal buyers for market research purposes and help identify the specific environmental consulting services contractors offer.
As with all service-based SINs, offerors will need to prepare one past performance narrative identifying how the services performed for a commercial project align with the Environmental Consulting SIN’s description to have the SIN awarded. While the SIN’s description and the process to have the SIN awarded appear relatively straightforward, typical issues with offer rejection or rejection of a contract modification to add this SIN involve proposing services not procured under this SIN or at all within GSA MAS, which we will discuss next.
Occasionally, GSA will include special instructions or notes in addition to a SIN’s description in the applicable Category Attachment to the main Solicitation. For example, in the Professional Services Category Attachment, GSA includes a note for the Engineering SIN’s description stating this SIN does not include “architect-engineer services as defined in the Brooks Act and FAR Part 2, or construction services as defined in FAR Parts 2 and 36.”
While additional instructions and notes are absent under the Environmental Consulting SIN’s description, this lack of information doesn’t necessarily mean contractors can offer any type of typical environmental or A-E service through this SIN that they would for a commercial project. Contractors and offerors should instead review the instructions for the overall Environmental Services Subcategory to understand key requirements. Any SIN that falls within this subcategory does not allow contractors to offer the following services:
As noted above, the Environmental Consulting SIN is subject to the same construction and A-E service restrictions that apply to the Engineering SIN. A-E services, as defined by FAR Part 2, involve:
Although GSA’s Construction Management and Engineering Consulting Services Related to Real Property Implementation Guide is tailored to the Engineering SIN, this reference material is helpful in determining if a service is allowed under the Engineering SIN, and ultimately, the Environmental Consulting SIN, as both are subject to the same limitations with A-E services.
A few unauthorized services that are associated with the Environmental Consulting SIN and not clearly referenced under the Engineering SIN are:
While technicians with expertise in asbestos contamination are allowed under the Environmental Consulting SIN for advising purposes, asbestos abatement services are not allowed. It’s important to limit references in your proposed offerings and past performance narrative to asbestos abatement and the other unauthorized services described earlier and instead focus on the services outlined in the SIN’s description to avoid potential offer rejection.
In addition to the Environmental Consulting SIN, the Environmental Services Subcategory also includes the following SINs, each with their own set of offer or modification submission compliance actions:
These SINs require contractors to meet multiple insurance requirements, including workers compensation and employers’ liability insurance as required by law, general liability insurance, automotive liability insurance, and pollution liability insurance. Additional information and instructions regarding insurance coverage can be found in the Professional Services Category Attachment to the main Solicitation.
For the Environmental Remediation Services SIN, offerors must include a response to several prompts addressing practices in place if proposing remediation services related to the transportation, storage, treatment, and/or disposal of hazardous waste.
For the Hazardous Waste Disposal Services SIN, offerors are required to submit responses to prompts related to their processes for tracking and documenting materials, data security, electronic recycling, and similar items.
Further, if an offeror is proposing any medical or pharmaceutical waste disposal services, they must include additional documentation with their offer, such as a copy of their most recent external audit evaluating compliance with waste collection, transport, and/or disposal processes. If an offeror has not had an external audit or completed any internal audits, they are required to provide an explanation and provide insight into compliance with federal, state, and local regulations.
Additionally, this SIN does not allow contractors to perform services related to the transportation or disposal of asbestos and/or paint abatement, radon mitigation, and radioactive waste except for low-level radioactive waste associated with medical waste.
The steps to prepare a GSA Schedule proposal can be overwhelming and the varying requirements to have each SIN awarded can create additional obstacles during this process, such as with the Engineering or Environmental Consulting SINs. Considering the additional restrictions and compliance actions for these SINs, it can be difficult adapting your commercial offerings to the engineering or environmental services federal buyers are looking to procure through GSA MAS. Our consultants have experience in preparing offers and modifications for both SINs and are available to provide insight into best practices and any changing requirements.