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Although the single most important aspect of an

effective EEO program is commitment from top to bottom,

certainly the second most important consideration is an

efficient organizational structure. The development of

such a structure must consider the mission of EEO and the

larger organization within which it must lunction.

As stated in the introduction to this report, Equal

Employment Opportunity is the state that exists when all

people in any given employment can go as far as their

ability and willingness to accept challenge will take them.

But we recognize that because of discrimination and social

attitudes past and present, all people do not have an

equal start. Positive action is required to assure the

equitable representation of all races, sexes and ethnic

backgrounds throughout all levels of employment in the


In the Department of Labor this translates into

equi table distribution of all employees across all GS

grade levels. The methods to achieve this objective are

discussed elsewhere in this report.

The concern here is

how best to organize our efforts to reach this goal.

This section of the Task Force Report will examine

the present structure of EEO now and how the organization

can be improved to accomplish EEO goals.

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the Secretary of Labor directly to the heads of each

Administration and Office.

The heads of the A&O's de

signate EEO Co-ordinators to assist them in carrying

out their responsibilities.

The Assistant Secretary for

Administration is designated the EEO Director and is given

authority to provide leadership and assistance to the


There is, further, an EEO Officer who is to

assist the EEO Director, and who is responsible for

receiving formal complaints of discrimination.


Order also provides for EEO Counselors who are respon

sible for receiving informal complaints.

The Order states

that the A&O's must submit a yearly EEO affirmative action

plan to the EEO Director and include EEO progress in

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Secretary to the heads of A&O's, the Secretary's Order

immediately spreads responsibility for EEO in eight dir


This allows for a considerable amount of leeway

in EEO activity.

Furthermore, responsibility zigzags

back and forth from the A&O's to the Office of the

Assistant Secretary for Administration.

This results in

confusion as to where responsibility and authority lie.

(See Appendix E-l). As the Civil Service Commission

pointed out in a letter to the EEO Director dated Sept

ember 28, 1970:

"Our reaction is that the Plan does not

reflect enough personal involvement and positive direc

tion from the top levels of the Department.

It seems

to us that the Plan leaves too much to the discretion of

the various Administrations and Offices."

It also stated

that, "rather than being 'requested', each Administration

should be required to undertake job restructuring acti

vities, and they should cover more than one occupational

series." Along wi th criticizing the absence of central

ized EEO leadership, the letter faulted the Department's

Action Plan for merely stating good intentions while

specifying few concrete goals.

Another problem arising from the delegation of re

sponsibility to the A&O's is the lack of communication

among people who work in EEO.

There is no provision for

co-ordination of these programs and little actual exchange

of ideas. In fact, many individuals who are concerned

with EEO are completely unaware of what occurs in other


While the EEO Director receives EEO Plans from the

A&O's, he does not have the authority to set minimum

standards for these plans.

He is, however, held respon

sible by the Civil Service Commission for the Department

wide EEO Action Plan (which must cover the A&O's.)

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