A contractor's obligation to observe the provisions of the Act
arises on the date the contractor is informed that award of the contract
has been made, and not necessarily on the date of formal execution.
However, the contractor is required to comply with the provisions of the
Act and regulations thereunder only while the employees are performing
on the contract, provided the contractor's records make clear the period
of such performance. (See also Sec. 4.179.) If employees of the
contractor are required by the contract to complete certain preliminary
training or testing prior to the commencement of the contract services,
or if there is a phase-in period which allows the new contractor's
employees to familiarize themselves with the contract work so as to
provide a smooth transition between contractors, the time spent by
employees undertaking such training or phase-in work is considered to be
hours worked on the contract and must be compensated for even though the
principal contract services may not commence until a later date.
