complaints and counseling should be unified into one staff under the Director of EEO. b. The professional staff should cover (with one or more persons) the following functions: (see races, ethnic backgrounds, and sexes in the staffing 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. a. There should be a full-time EEO Co-ordinator 4. b. Plan for his A&O. At each layer of responsibility, the chief of that unit or sub-unit will be responsible for EEO programs and goals for all the employees beneath him. EEO in the Field 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. and complaints system in his region and 5. b. iii. iv. V. supervise the full-time recruiter. receive formal complaints from his region. provide communication in EEO matters for each A&O represented in his region. provide on-the-spot evaluation of EEO pro grams in his region. Every A&O should designate someone on the staff of each Regional Administrator as Deputy EEO Co ordinator who would: i. ii. be part-time in that capacity. report to the EEO Co-ordinator in the N.O. iii. work closely with the Regional EEO Officer. Office of Personnel OP should coordinate affirmative action programs, particularly recruitment but it should operate from 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 employees which is totally outside both EEO and Personnel. VI. GOALS AND TIMETABLES Our statistics have indicated the serious underutil ization of Blacks, Women, and Nonblack Minorities 2/ 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 3/ 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 underutilization. The plan is organized pursuant to Secretary's Order 39-69 (see Appendix F-2) and allows each A&O to formulate its own EEO policy. This delegation of responsibility 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. |