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races, ethnic backgrounds, and sexes in the staf

fing of this office in order that all points of view

will be available in the interaction of the staff

and to avoid the necessity of having a "specialist"

for each racial-sexual group.

d.

All the individuals hired for this office

(or any EEO function anywhere in the Department)

should:

i.

have some EEO experience or background.

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a.

There should be a full-time EEO Co-ordinator

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that unit or sub-unit will be responsible for EEO

programs and goals for all the employees beneath him.

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a.

There should be a full-time EEO Officer in each

region (attached to the Regional Director) who will:

i.

report to the EEO Director in the N.o.

ii.

co-ordinate the part-time EEO Counselors

and complaints system in his region and

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V

provide on-the-spot evaluation of EEO pro

grams in his region.

b.

Every A&O should designate someone on the staff

of each Regional Administrator as Deputy EEO Co

ordinator who would:

i.

be part-time in that capacity.

ii.

report to the EEO Co-ordinator in the N.o.

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regular OP units rather than a special EEO unit.

Great

care should be taken to define EEO responsibilities to

avoid duplication.

6.

Continuing Evaluation of EEO in DOL

There should be an evaluation of the status of EEO

in DOL every five years by a full-time group of DOL em

ployees which is totally outside both EEO and Personnel.

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VI.

GOALS AND TIMETABLES

Our statistics have indicated the serious underutil

ization of Blacks, Women, and Nonblack Minorities2/

in

the Department's workforce. This underutilization is most

prevalent in the professional grades, but also exists in

the clerical grades, especially in the Field.

Present departmental efforts toward achieving full

utilization of minorities and women are minimal.

The

Department's EEO Action Plan for FY :71 (see Appendix F-1)

is a series of general policy statements which fail to

deal effectively with the specific causes of underutiliza

tion.

The plan is organized pursuant to Secretary's Order

39-69 (see Appendix F-2) and allows each A&O to formu

late its own EEO policy.

This delegation of responsi

bility results in many different approaches toward

1/

The condition that exists when a group is either inequitably distributed in the workforce, inequitably represented in the workforce, or both.

2

Spanish-surnamed Americans, American Indians, and Orientals.

3/ Same as parity sentation.

equitable distribution and repre

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