available and that contracting agencies would be in a bet

ter position to enforce the contractual EEO requirements.

Recommendations:

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.

3.

Location Within the Department of Labor

Findings:

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

administration.

Recommendations:

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.

1.

PART III

REGULATORY STANDARDS--CHAPTERS 5-8

Affirmative Action Requirements of the Executive Order
--Supply and Service Contractors

Findings:

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:

a.

b.

C.

d.

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
programs and other affirmative action procedures,
to increase the supply of minorities and women
when their representation in specific job groups
is negligible needs to be clarified.

For purposes of conducting the job group anal-
ysis, conducting the availability analysis,
and setting goals, the definition of a job
group does not adequately recognize job fami-
lies or rigid progression sequences and is so
narrowly framed as to frequently create job
groupings which are too small for meaningful
goals.

Interpretations which have expanded the concept
of goals and timetables to provide for the
achievement of "ultimate goals" and "annual or
interim goals" have created administrative

e.

difficulties arising from the fact that at

tempts to predict job vacancies over a long

term are impractical.

The procedural requirements of the affirmative
action program regulations, which contain spe-
cific methods and techniques for making the
program work toward achieving nondiscrimina-
tion and affirmative action objectives, have
proven to be burdensome and, in many instances,
to divert the attention (including resources)
of contractors and the Government from "bottom

line results."

Recommendations:

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:

a.

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

statistical area.

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

terms.

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

5 years.

OF MICHI