Accounting Office, the Congressional Joint Economic Committee and the Equal Opportunity Subcommittee of the House Committee on Education and Labor. The views of the Subcommittee are partially reflected in the following exchange between former Secretary of Labor John Dunlop and Congressman William Clay of Missouri:

SECRETARY DUNLOP:
Now I take it what you
are saying to me, and I want to be sure I
understand it, is that you are raising the
question of what might be described as the
status or image or perception of the im-
portance of the program in the Department
by virtue of its location in the hierarchy
of the Department. Is that right?

MR. CLAY:

I think it is much deeper than that, Mr. Secretary.

SECRETARY DUNLOP: Well, help me.

MR. CLAY: It has nothing to do with image
and status as such. It has to do with the
general thinking of the people who are run-
ning the Department of Labor whether or not
this program is going to be put on par with
the other priority programs over there. I
think for the past 4 or 5 years it has been
constantly downgraded.

A similar view was expressed by the minority

2

member of the subcommittee, Congressman John Buchanan of Alabama, in an exchange with the Solicitor of Labor:

3

2.

Hearings before the Equal Opportunity Subcommittee

of the House Education and Labor Committee, June 18, 1975, p. 137.

3.

III.

MR. BUCHANAN:
I should, in all can-
dor, indicate that I share some of my col-
leagues' feeling that a man's position
within the hierarchical structure of a
department does bear some relationship
to the importance attached to his func-
tion in that department. I therefore
would urge, given this good beginning,
that you would consider the possibility
of the assistant secretaryship position
being restored.

Recommendations

Three basic options for restructuring the OFCCP program in the Labor Department are discussed below.

A.

Federal Contract Compliance Administration With the consolidation of the total Federal contract compliance program within the Department of Labor, OFCCP will have complete responsibility for a compliance and enforcement program covering some 29,000 contractors employing approximately 31 million persons, affecting the Federal Government's total procurement budget.

This fact, coupled with the program's staff and budgetary resources of over 1,900 positions and $42 million justifies the creation of a Federal Contract Compliance Administration under the leadership of an Assistant Secretary. In addition to enabling the Department to overcome problems relating to research planning, administrative support, coordination and field operations, the elevation of the

contractors alike that the enforcement of equal employment opportunity carries a degree of priority within the Department of Labor at least equal to that of Employment and Training, Occupational Safety and Health, Employment Standards, and other programs for which the Department has responsibility.

B.

Employment Rights or Equal Rights
Administration

This structure would be essentially the same as that described above but with the addition of the Equal Pay and Age Discrimination activities and/or the addition of the activities of the Women's Bureau. A primary consideration, however, is whether OFCCP has the capability to take on added responsibilities prior to demonstrating its capability to institute the reforms necessary to realize its maximum potential under the Executive Order, Section 503 and Section 402 and to achieve optimum EEO results after such reforms have been put in place. The Task Force doubts the ability of OFCCP to take on any such additional responsibilities within the next 1 to 2 years.

c.

Employment Standards Administration

The Task Force finds that forces against OFCCP's

complete success in its current location are more institutional than related to the personal attributes

of remaining in the Employment Standards Administra

tion poses three central questions:
(1) whether the
fundamental structure, systems, and procedures of ESA

can be revised in such a manner as to accommodate
OFCCP's basic needs; (2) whether that accommodation
can be institutionalized so that effective operation does
not depend upon the leadership of a single individual;
and (3) whether a system which institutionally accommo-
dates the needs of OFCCP adversely affects the effective-
ness of ESA's other program activities--Wage Hour (in-
cluding Age Discrimination and Equal Pay), Women's
Bureau, Federal Employees Compensation, Longshore and
Harbor Workers, and Black Lung.

PART III

REGULATORY STANDARDS