COMPLIANCE WITH THE RANDOLPH-SHEPPARD ACT
IN LEASING AND CONSTRUCTION
ISSUE:
General Counsel, in light of recent litigation experiences and discussions with the
Department of Justice, has concluded that VA needs to comply with the Randolph-
Sheppard Act to the extent possible while preserving the special status enjoyed by
the Veterans Canteen Service under its creating legislation.
BACKGROUND:
Congress passed the Randolph-Sheppard Vending Stand Act to require Federal
agencies to give priority to blind vendors in establishing vending concessions on
Federal property. Until recently, VA had taken the position that the law
establishing the Veterans Canteen Service exempts VA from compliance with
Randolph-Sheppard.
DISCUSSION:
Whenever VA plans to: occupy, acquire, relocate, or substantially renovate or
alter a building, the appropriate State Licensing Agency must be notified so that a
satisfactory site for the location and operation of a vending facility can be made
available for use by a blind vendor.
A satisfactory site is defined as a minimum of 250 sq. ft. available for the vending
and storage of articles necessary for the operation of a vending facility, including
sufficient electrical, plumbing, heating and ventilation outlets for the location and
operation of a vending facility.
RECOMMENDATIONS/CONCLUSION:
The Act is applicable to any building in which more than 99 Federal employees will
be located during normal working hours or which contains 15,000 sq. ft. or more of
interior space to be utilized for Federal Government purposes.
FOR ADDITIONAL INFOR MATION:
Contact George Szwarcman at 202-565-5026 or Dean Miller at 202-565-6863.
23 July 1996
FM-187C-DA57
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