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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
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
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
Although the Executive Order assigns primary
responsibility for enforcing the EEO contractual obligations to the compliance agencies, it also author
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
out under the line authority of an ESA regional ad
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
To one degree or another, many of the problems
outlined above have been disclosed in the findings of