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.

Two administrations, Manpower and ESA, have fulltime EEO specialists in their personnel divisions.

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.)

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.

The Chief of the EO Group is the highest ranking person in DOL who is occupied full-time with EEO. It 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 neces

sarily 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