6. Constraints

Although the exact percentage will not always be

achieved, a general constraint, applicable to all groups

This

for whom goals are being set, should be established. constraint, which will limit the amount of deviation allowed from the stated goal, is that the average salary of a

black employee in a particular grade grouping29/j

is not to

differ by more than one percent from that of all employees

In addition to this salary constraint, there must be

White

a constraint on the percentage which males and females comprise of all white and black professionals. females should comprise between twenty-five and thirty percent of all white professionals, and black females are to represent between forty and sixty percent of all black professionals. These percentages reflect approximately the representation of each group in the national workforce, will prevent supervisors from hiring only minority females to achieve their goals.

and

29/

The groupings will differ according to an organization's grade structure; ex. GS 5-9, GS 11-13, etc.

30/

All salaries to be calculated on the basis of Step 1.

7.

Nonprofessionals in the Field

Numerical and percentage goals must also be established for filling nonprofessional jobs in the Field,

because minorities are under-represented at these lower levels in all of the eight regional administrative

offices.

31/

The main criteria used should be the percen

tage which the particular minority group comprises of the local population (SMSA). At present, the largest disparities exist in the Atlanta region where blacks are 51% of the local population, but only 12% of all nonprofessional employees, and the Philadelphia region where nonblack minorities comprise approximately 15% of the population in the metropolitan area but have no representation 32/ in the nonprofessional ranks.

8.

Implementation of Goals and Timetables

Past efforts to significantly increase the representation of minorities and women in the Department or in

31/

32/

See Appendix A

The Department should also take affirmative action to assure that minorities and women are equitably represented and distributed throughout the nonprofessional grades in the Field.

particular areas of the Department have often ended in

failure.

Recently, with the opportunity to staff a new organization, the Occupational Safety and Health Admin

istration, that could be a model for the Department,

goals were established and minority recruitment efforts

were initiated.

Yet, when the staffing was completed,

OSHA was no better than the Department overall. A 12% goal for minorities at each grade level was achieved only up to GS-12 in the National Office, and achievement was considerably poorer in the Field. The number of Spanish Americans recruited was considerably below equity.

But,

the worst record was with respect to women; the OSHA staff is comprised of only 3% women. (See Appendices C-9 and

C-10 for the actual statistics).

Similar frustrated

efforts have been recurring in ASPER, which still employs only one minority among 26 professionals.

These and other

examples point to a high casualty rate for good EEO intentions in the Department, even when they are stated in specific terms (i.e., as numerical goals). One is forced to conclude that establishing numerical goals is not sufficient in itself. Systems must be designed which can

provide for effective implementation.

Explanations of Past Performance

A consideration of explanations of past failures

should be helpful in suggesting management approaches

which would be more successful in the future. Six such

reasons will be mentioned.

First, goals have often not been clear and specific. Or, if they were, they were not well communicated.

Second, no specific persons were given responsibility for goal achievement in the various units of the Depart

ment.

Third, no corrective measures were available to handle cases in which goals were not achieved.

Fourth, no management systems were utilized for con

trol and coordination.

In a large organization, this is

essential to mount and sustain a program as high priority for all management levels.

Fifth, no definitive guidelines and responsibilities existed for the involvement of first-line supervisors. Inasmuch as these supervisors make most of the personnel selections, any EEO program which does not charge them with

specific responsibilities and provide guidelines for im

plementation is doomed to failure.

Sixth, information on staffing has generally been

inadequate.

Many persons concerned with furthering opportunities for minorities and women through affirmative action become aware of available positions only after they are filled, often with neither a minority nor a woman. Lacking detailed data on staffing patterns, managers are not as aware of female and minority underutilization and they are unable to direct, support, and monitor the actions necessary to resolve deficiencies.

Proposals for Effecting Implementation

Effective implementation is the result of sustained commitment, careful planning, and continual review and Achievement of EEO goals in the Department

monitoring.

will result from a program containing these elements. Furthermore, to succeed, any Departmental EEO effort must be designed to overcome the past deficiencies mentioned

above. The four proposals which follow satisfy these

prerequisites.

First, the Department must initiate a system of numerical goals and timetables Department-wide and down to the smallest organizational units. The proposals for goals and timetables already discussed provide for such a system (see