Challenge To OCI Waiver Falls Short
Client Alert | 1 min read | 09.09.10
In MCR Fed., LLC (Aug. 17, 2010) GAO denied the protester's challenge to the agency's decision, in the context of taking corrective action, to waive organizational conflicts of interest for two offerors to facilitate competition, noting that, "[w]here a procurement decision -- such as whether an OCI should be waived -- is committed by statute or regulation to the discretion of agency officials, our Office will not make an independent determination of the matter." GAO found that the agency complied with FAR 9.503, including approval by the agency head's designee and a written determination setting forth (i) the extent of the conflict and (ii) explanation for why application of the OCI rules would not be in the government's interests in the particular procurement.
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Client Alert | 4 min read | 04.08.26
Cosmetics Under the Microscope: FDA’s Expanding Regulatory Reach Under MoCRA
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) marked the most significant expansion of FDA’s authority over cosmetics in 80 years — and the agency is putting that authority to work. From the launch of a new adverse event reporting tool to forthcoming rules on fragrance allergens and good manufacturing practices (GMP), FDA is reshaping the regulatory landscape for manufacturers, packers, and distributors of cosmetic and personal care products.
Client Alert | 11 min read | 04.08.26
Client Alert | 3 min read | 04.07.26
Answering the Top Seven Questions About Pending Section 301 Deadlines


