cause notices or notices of intent to debar. The Department must develop an affirmative action plan 13/ containing numerical goals and timetables in order to achieve equitable representation and distribution of minorities and women throughout its workforce. 12/ Rules and Regulations CFR 60-1.28 Show Cause Notice. When the Director (of OFCC) has reasonable cause to believe that a contractor has violated the equal employment opportunity clause, he may issue a notice requiring the contractor to show cause, within 30 days, why monitoring, enforcement proceedings or other appropriate action to insure compliance should not be instituted. CFR 60-1.26 (2) Cancellation, termination, and debarment. S 13/Order No. 4, §60-2.10; an affirmative action plan is defined as "a set of specific and result-oriented procedures to which a contractor commits himself to apply every good faith effort." The application of such efforts toward achieving the specified objectives is regarded as equal employment opportunity. Numerical goals and timetables are necessary for both ethical and practical reasons. The Department, through OFCC, is very instrumental in imposing this re quirement on others and should, therefore, make the same requirement of itself. Furthermore, the Department's role in enforcing and setting compliance policy would be facilitated and its credibility increased if it set sim ilar standards for itself. Affirmative action is also required because a mere negative prohibition against discrimination is not sufficient to deal with the problem of underutilization. Minor ities and women would continue to suffer from the effects 14/ of institutional discrimination without positive efforts in the areas of both upgrading and recruitment. In addi tion, a policy to merely non-discriminate would have little effect in overcoming the credibility gap which might exist between an organization and its underutilized groups. For practical reasons, numerical goals and timetables are necessary because they clearly state policy objectives and establish specific time schedules within which to meet them. The Civil Service Commission has recognized that goals and timetables are "a useful management concept" 15/ and has already approved affirmative action plans submitted by the Office of Management and Budget and the Department of the Army containing this concept. The Department of Labor must project the image of a model employer by establishing numerical goals and timetables for those groups presently underutilized in its workBlacks, Women, and Nonblack Minorities, and these goals and timetables should be based on result-oriented force criteria. 4. Guidelines for Affirmative Action The establishment of criteria for numerical goals and timetables is an effective beginning toward the development of a successful affirmative action plan. These criteria can be used to evaluate the present position of minorities and women in the Department and to formulate appropriate numerical goals and timetables, which are to be re-adjusted when necessary according to the contents of the criteria. 15/Civil Service Commission memo of May 11; see Appendix F-6. The following set of criteria should be used to es tablish meaningful numerical goals and timetables in order to achieve the full utilization of minorities and women in the departmental workforce; 1) availability, 2) representation in the society both in national and local popu lations, and in the workforce, 3) parity, and 4) the role and mission of the Department of Labor. a. Availability includes the following factors: i. ii. iii. The number of minorities and women within a profession of particular interest to the the number of qualified departmental employees who, having the skills necessary for promo tion, are presently being underutilized; the percent of women and minorities in both the workforce and the labor force;17/ 16/ These occupations include Law, Guidance and Counseling, Accounting, Economics, Political Science, Mathematics, Social Science, Business Administration, Sociology, Journalism, Industrial Relations, and International Relations. iv. the job slots available through attrition, and through turnover and expansion of the workforce. 18/ b. The percent, both present and projected, which a 19/ 18/ The availability of minorities and women in occupations of interest to the Department should increase. Career opportunities for these groups should improve as a result of changing social and cultural attitudes, and this factor will be instrumental in determining appropriate numerical goals and timetables for a particular underutilized group. 19/This population is to be taken from the Standard Metropolitan Statistical Area (SMSA). SMSA the metropolitan population: Except in New England, an SMSA is a county or group of contiguous counties which contain at least one city of 50,000 inhabitants or more, or "twin cities" with a combined population of at least 50,000. In addition to the county or counties, containing such a city or cities, contiguous counties are included in an SMSA if, according to certain criteria, they are essentially metropolitan in character and are socially and economically integrated with the central city. In New England, SMSA's consist of towns and cities, rather than counties. Current population Reports Population Characteristics Household March, 1970 U. S. Department and Family Characteristics of Commerce/Bureau of the Census, p. 4. |