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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:2

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.

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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

member of the subcommittee, Congressman John Buchanan

3 of Alabama, in an exchange with the Solicitor of Labor:

?Hearings before the Equal Opportunity Subcommittee of the House Education and Labor Committee, June 18, 1975, p. 137.

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.

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With the consolidation of the total Federal con

tract compliance program within the Department of Labor,

OFCCP will have complete responsibility for a compli

ance 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 Con

tract Compliance Administration under the leadership

of an Assistant Secretary.

In addition to enabling

the Department to overcome problems relating to

research planning, administrative support, coordina

tion and field operations, the elevation of the

contractors alike that the enforcement of equal em

ployment opportunity carries a degree of priority

within the Department of Labor at least equal to that

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that described above but with the addition of the Equal

Pay and Age Discrimination activities and/or the addi

tion of the activities of the Women's Bureau.

A pri

mary 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 responsibili

ties within the next 1 to 2 years.

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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

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