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available and that contracting agencies would be in a bet
ter position to enforce the contractual EEO requirements.
The responsibility and authority, including budget and staff resources of the compliance agencies must be consolidated within the Department of Labor. In addition to eliminating the major obstacles to successful program performance the consolidation would achieve a cost savings of 8 to 10 million dollars which could be used to increase compliance review coverage by 25 percent.
Location Within the Department of Labor
Serious problems relating to the rank, status, independence, and degree of priority afforded OFCCP within the Department of Labor have been with the organization since its assignment to that agency. Because the organization did not have total administrative and implementation responsibility for the Executive Order Program, it could not be placed at a high policy level as an autonomous, self-contained unit with adequate support services. Total consolidation within the Department of Labor would provide administrative justification for a separate
Consideration should be given to the reconstitution of OFCCP within the Department of Labor as an autonomous Federal Contract Compliance Administration under the leadership of an Assistant Secretary of Labor who has EEO enforcement as his/her sole responsibility. The Secretary of Labor should also consider the eventual inclusion of other equal employment related activities within that administration. Alternatively, the Depart
ment of Labor could examine the possibility of effecting such institutional changes in the Employment Standards Administration as may be necessary to permit OFCCP to realize its full potential as a program within that organization.
REGULATORY STANDARDS--CHAPTERS 5-8
Affirmative Action Requirements of the Executive Order
There can be little doubt that OFCCP's affirmative action program goals, timetables, and procedures for supply and service contractors have produced significant numbers of new job opportunities for minorities and women. However, OFCCP has not yet developed systems which enable it to assess the precise quantity and quality of such opportunities and, for enforcement purposes, to iden
tify all contractors who may be failing short of their full goal and timetable commitment.
In addition, several of
the affirmative action requirements need to be improved
for the purpose of creating greater efficiency and
achieving greater results:
Data which purport to reflect the availability
of minorities and women in the labor force
for the purpose of determining the necessity
for and level of goals are not available in an easily used format.
The obligation of contractors, through training
For purposes of conducting the job group anal-
Interpretations which have expanded the concept
difficulties arising from the fact that at
tempts to predict job vacancies over a long
term are impractical.
The procedural requirements of the affirmative
To measure the success of the affirmative action
goals and timetables obligation, OFCCP should incorporate into the affirmative action program regulations, the requirement of a coding sheet which summarizes data and information from the body of the program. Summary would include goal and timetable accomplishments during the preceding year, accomplishments projected for the upcoming year, and related evaluative data and information which would permit an assessment of OFCCP's performance based upon new opportunities created for all program beneficiaries. To achieve greater efficiency and to
improve affirmative action results these additional
measures are recommended:
The Department of Labor should develop reasonably precise and adequate availability data and establish benchmarks for the industrial job
groups by labor market or standard metropolitan
b. To insure that affirmative action efforts effectively address those job groups or specific occupations for which both incumbency and
availability are minimal, the Department of
Labor should develop other methods to trigger
goal setting requirements.
C. To assist in assuring that all goals are signif
icant and attainable, the definition of job
group should be reframed in somewhat broader
d. To address the problem of meaningless longrange predictions and, at the same time, keep goals and timetables within the framework of the fundamental principles of remedy, the Department should establish the requirement of multiyear goals and timetables, not to exceed