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implementation of a reasonably precise and efficient

set of priority criteria for the selection of con

tractors for compliance reviews and investigations;

(2) a data system which serves as a basis for deter

mining the efficacy of its regulatory policies and

procedures, including the extent to which the affirma

tive action program goals and timetables requirements

and the affected class discrimination policies are

producing new and better job opportunities for minori

ties and women; and (3) research studies from which

reasonably adequate estimates can be made of the

availability of minorities and women for employment in job groups from which they have been customarily

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ther, the office has had to compete with other programs

within ESA for the limited increases contained in the

organization's annual requests; and, more often than

not, allocation decisions apparently have been based primarily on considerations largely unrelated to actual

that Executive Order 11246 has ranked high on

ESA's list of priority programs.

ESA's personnel management services have been

even less helpful than its other support activities.

Following the departure of Assistant Secretary Fletcher,

OFCCP was reorganized to bring its grade structure

more in line with other ESA operating units despite

the staff/line relationship between the office and the

compliance agencies which distinguishes the organiza

tion from other Employment Standards programs.


executive level positions were reduced in number from

10 to 6, and the supervisory and senior specialists

positions were reduced in number from 16 to 5.


impact of the reorganization was to destroy the cor

porate/career ladder relationship between OFCCP and

the agencies under which the office was able to attract

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personnel to the extent that those to whom the OFCCP

staff is charged with the responsibility of providing

levels. The disparity in status and levels of, authority and responsibility has not strengthened OFCCP'S

capability to exercise supervision over the compliance



Investigative Resources

Although the Executive Order assigns primary

responsibility for enforcing the EEO contractual obligations to the compliance agencies, it also author

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However, its staff resources did not expand at the

rate at which such plans developed.

In the spring

of 1973 and the summer of 1974 investigative staff

from other divisions in ESA were temporarily assigned

to assist in the conduct of audits of areawide con

struction industry plans and bid conditions.


that time no compliance operations support has been

forthcoming; and, for lack of sufficient OFCCP staff

construction industry have not been sufficient to permit

those plans to realize their potential.

In addition, insufficient staff is available to

investigate difficult or unprecedented nonconstruction

cases, although significant remedies have been obtained

in the past through direct involvement in such matters.


Coordination with Other Federal Agencies and with Other Department of Labor Programs

The Director's ability to assure effective coordi

nation and mutual support in equal employment oppor

tunity enforcement has been hampered because of

organizational placement in DOL, by the lack of access

to the Chairman, general counsel, and other policy

and decision making officials of EEOC and the Assistant

Attorney General for Civil Rights of the Department of


Within the Department, the absence of interaction

at a peer level with other program officials has, in

large part, prevented the necessary coordination between

OFCCP, and other Department of Labor programs to achieve

data support for affirmative action programs, compli

ance reviews, target selections, success measurements,

and for job training and placement activities.


those programs are the Bureau of Labor Statistics,

Employment and Training Administration, and Office of

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out under the line authority of an ESA regional ad

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ill-defined, somewhat subjective, and in a constant

state of development.

Thus effective performance de

mands that the OFCCP National Office exercise a greater

degree of direction, control, and supervision over its

field operations than ESA's management system has



Other Problems

To one degree or another, many of the problems

outlined above have been disclosed in the findings of

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