Although the Federal Personnel Manual (713-9 para

graph b) states that the EEO Officer shall assist in carrying out the Agency's EEO program and that his functions in support of the EEO program will involve him in the affirmative action aspect of the program, the Department of Labor's EEO Officer (as assigned by Sec. Order 39-69) is concerned only with the complaints system. Employed full-time as the Division Chief for LaborManagement Relations, he can only devote a small part of his time and energy to his EEO duties. As EEO Officer he is responsible for a network of 30 EEO Counselors, 14

in the National Office and 16 in the Field. He is al so

responsible for making sure all employees are aware of their rights in discrimination complaints and who the

EEO Counselors are.

Unfortunately, the amount of atten

tion he can give to his work has been severely limited due to increased responsibility in his regular full-time job. He has been unable to assure public posting of the lists of counselors, or replace counselors who have quit or moved, let alone keep the lists of counselors up-todate. The incumbent EEO Officer feels strongly that this

position should be given to someone who could devote

full time to it.

Furthermore, while formal and informal complaints often point to patterns of discrimination and underutilization, which can only be handled through affirmative action, there is no organizational relationship between the EEO Officer and the EO Group. Both are located in the Office of Personnel, but the EEO Officer generally reports directly to the EEO Director in his equal opportunity capacity and this effectively separates the complaint function from the affirmative action function. In times of crisis, the Chief of the EO Group does meet with the EEO Officer but not on a regular basis.

It

The Chief of the EO Group is the highest ranking person in DOL who is occupied full-time with EEO. should be pointed out that a GS-14 Unit Chief has little status when dealing with top level EEO Co-ordinators of the A&O's. Nor does the unit have enough staff to carry out the planning, evaluation, research and co-ordination required for an effective Department-wide affirmative

action plan.

In the Field, organizational problems are considerably worse. There is no full-time EEO personnel.

Nor

do the regions have training officers actually in the Field, even though the largest regions have approximately 1,000 employees. (Manpower regional training officers are mainly concerned with external training.) In Chicago, for example, office directors decide who will be trained and the papers are processed by a personnel management specialist with many other duties to perform.

a. The organizational structure of EEO should provide for a unified, central office with responsibility for policy development and authority to set minimum standards and evaluate results. This would not necessarily hinder creative efforts on the part of individual A&O's but it would ensure that all of the Department's employees are given adequate EEO consideration.

b. The Central Office should have adequate staff to carry out the responsibilities of the office with efficiency and creativity.

C. The organization should provide for co-ordination and communication between people involved in EEO

activity throughout the Department.

People have a ten

dency to be defensive about EEO. This does not help to

solve the problems that arise in trying to implement an Individuals working in this field

effective program.

should be encouraged to share both their problems and their successes in order to help and be helped by other people who have met similar situations.

d. The organization should provide more status

to full-time occupation with EEO. The heads of A&O's and the Secretary of Labor are held accountable for EEO in their organizations. They need experienced EEO experts who have enough status to be able to influence the managers and supervisors who must implement the pro

grams.

e.

The organization must allow for the appropriate EEO consideration of the nearly 5,000 employees in the

a. The EEO Director should be full-time and placed

along with a full staff in one of the following

positions:

b. The EEO Director must have had a good back

ground of EEO experience.

C. The EEO Director should have the responsibility

and authority for:

i.

ii.

iii.

iv.

developing Department-wide policy for

EEO;

setting minimum standards for the A&O's; evaluating the EEO programs of the A&O's;

providing communication and co-ordination