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V. ORGANIZATION OF EEO

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 iunction.

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 society. In the Department of Labor this translates into equitable 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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Equal Employment Opportunity in the Department of Labor is organized following the Secretary's Order

39-69.

This delegates the responsibility for EEO from 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

A&O's. There is, further, an EEO Officer who is to

assist the EEO Director, and who is responsible for receiving formal complaints of discrimination.

The

Order also provides for EEO Counselors who are responsible 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

their Quarterly Review and Analysis.

2. Other EEO Positions

The Secretary's Order does not designate a position

with responsibility for affirmative action below the level of the EEO Director. In response to this need, the EO Group was established in the Division of Departmental

Personnel under the Director of Personnel.

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By delegating responsibility directly from the Secretary to the heads of A&O's, the Secretary's Order immediately spreads responsibility for EEO in eight directions. 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-1). As the Civil Service Commission pointed out in a letter to the EEO Director dated September 28, 1970: "Our reaction is that the Plan does not reflect enough personal involvement and positive direction 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 activities, and they should cover more than one occupational series." Along with criticizing the absence of centralized EEO leadership, the letter faulted the Department's Action Plan for merely stating good intentions white

specifying few concrete goals.

Another problem arising from the delegation of responsibility 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

Administrations.

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 responsible by the Civil Service Commission for the Departmentwide EEO Action Plan (which must cover the A&O's.)

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