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These plans (38 remain operational) currently cover

geographical areas ranging from one county to entire

states.

They have goals for participating crafts which

are as much as 800 percent of the local minority work

[blocks in formation]

in existence for many years, OFCCP regions vary widely

in the severity with which "good faith effort" by par

ticipants is evaluated in the event that goals are not

met.

Because of the widely disparate goals and compli

ance standards applied, no real measurement of the num

bers of minorities permanently placed in the industry is

possible.

OFCCP does know, however, that few, if any,

of the voluntary plans approved have ever met their

goals.

Nationwide Heavy Highway Plan

National and Heavy Highway Plans are variations of

the Hometown Plan concept, involving usually one or a

limited number of craft unions either nationally or state

establish goals on a large geographic basis for partici

pating crafts and relieve contractors using these crafts

of responsibility for any compliance standards established

under other bid conditions in the area for nonparticipants.

Evaluation of the larger plans is also an OFCCP

regional responsibilit

As with Hometown Plans, there

has been little measurable progress and standards of

evaluation have been even less well defined than for the

[blocks in formation]

The Part II provisions apply to all nonparticipating contractors and to participating contractors for craft

unions which are not participating.

When approval is

withdrawn from a plan all contractors are subject to the

Part II provisions.

The Part II goals were generally

based on the goals for craft unions signing the voluntary

Monitoring and enforcement of the Part II requirements is the responsibility of the designated compliance

agency, usually the contracting agency.

The Construc

tion Compliance Manual provides the first formal system

for OFCCP to resolve cases where more than one agency

[blocks in formation]

them, at least quarterly, of serious deficiencies.

Imposed Standards

In a few of the 115 urban areas targeted for Home

town Plan development, standards have been imposed when

no plan was developed or an existing plan failed.

The

general language of these requirements is almost identi

cal to that of Part II in Hometown Plan areas.

These

bid conditions were published in the Federal Register

and still contain a certification requirement for bid

ders.

Goal computations for the imposed standards were

complicated, involving estimates of current union mem

bership and future vacancies.

Monitoring and enforcement of the imposed standards

Nonplan Standards

In mid-1976, Special Bid Conditions were first

issued for use in areas not covered by hometown or

[blocks in formation]

using 1970 census data and apply only to the aggregate

work force of contractors working on the specific

project.

Monitoring and enforcement of these standards is

the responsibility of the compliance agency and is simi

lar to that for part II and imposed standards.

[blocks in formation]

2.

Exemptions--hometown or imposed standards

have been exempted for union locals whose

[blocks in formation]

ance agencies, historically have felt that the

agency's project, rather than the contractors'

work force should be their primary focus.

From 1971 until mid-1976, the program was continually

expanded, redirected, and redefined in a piecemeal fash

ion.

No substantive revisions in the basic 1971 documents

were made during those years.

In August 1976, the Op

erations Manual for the Construction Compliance Program

was issued.

This Manual, issued with a revised reporting

format, standard form 257, standardized required proce

dures, systems, and reporting. Although implementation of the Manual by all OFCCP regions and compliance agen

cies was ordered on October 1, 1976, implementation has

been slow and varies widely within the program.

As described earlier, inconsistencies in the stand

ards used to measure compliance with the order exist.

Because of the emphasis on numerical standards rather

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