be the appropriate guideline when considering the nonprofessional ranks. This distribution is made since

the Department is a national recruiter for all of its

professional positions, but a local recruiter for its
20/
nonprofessional positions.

The percent of women in the full-time, year-round
professional workforce should be used as a guideline
in establishing a minimal goal for female representa-
tion and distribution in the professional grades. This
percent is employed instead of their percentage of the
national population, 51%. Enough women are not pre-
sently in occupations of interest to the Department
to meet a goal of 51%, and representation in the work-
force is more indicative of their availability.

C. Parity is the equitable representation and distribution of all groups throughout the Department's workforce. It will be achieved only when minorities and

20/ The Department has a Nation-wide impact through its programs and policies and, therefore, recruits its professionals on a National basis. It does its recruiting for nonprofessional positions on a local basis, for practical reasons. It would be impractical, for example, to recruit nonblack minorities from the Southwest for GS-3 positions in the National Office unless the effort was part of a special program.

women are represented and distributed in different

occupational categories and grade levels in the same manner as all employees.

Priority should be given to achieving parity for

all groups, but special attention should be given the group furthest below the condition of parity at any given time. This "worst first" doctrine means that, when the situation arises, an administration should hire or promote a member of the most underutilized group before anyone else, including members of other underutilized groups. This approach to upgrading and recruitment would bring the most underutilized group up to the status of the next most underutilized group and would continue until parity was achieved for all

groups.

d.

The role and mission of the Department justifies the establishment of higher numerical goals and more demanding timetables than could otherwise be developed by employing only the first three criteria. The Department has an obligation to establish a model affirmative action plan, because of its role in promoting and

5.

protecting the welfare of all wage earners, present

and potential. In addition, an equitable represen-
tation and distribution of all racial-sexual groups
throughout its workforce would help the Department

be more responsive programmatically to the needs of
its constituency, many of whom are women and/or mem-
21/
bers of minority groups. Making similar require-

ments of itself would also help the Department when

enforcing standards externally.

Proposals for Goals and Timetables

Representation in the national population or in the workforce, whichever is appropriate, is the first guideline used in determining the minimal percentage goal for an underutilized group. Availability of underutilized groups in particular occupations within and outside of the Department contributes both to the goal and to the timetable necessary for achieving the goal. The role and mission of the Department adds to the minimal goal, while the criteria of parity is used to evaluate the Department's present position, and to establish minimal goals. The goals proposed here apply to each National Office and Field unit of each administration.

21/

The racial composition of the professional grades in the Field should vary from region to region according to the racial composition of the regional population.

Parity, or the full utilization of all employees, is

to be achieved through the establishment and attainment of

both the percentage goals and the numerical goals, both of

which shall apply to Blacks, Women, and Nonblack Minorities.22/

The numerical goals are to be set annually in

23/

each A&O down to the smallest work unit.

The minimal

percentage goals are to be established at the A&O and Departmental levels, and are to be reached through the annual attainment of the numerical goals. The timetables for their achievement will vary and are to be set by the indi

vidual A&O, subject to the EEO Director's approval.

a.

Blacks are to comprise at least 12% of the profes

sional workforce.

In the National Office, they should comprise at least this percentage of all employees

at each professional grade level in each A&O.

In

the Field, each A&O must attain this minimal

22/The use of goals is not intended to and shall not

be so utilized as to result in discrimination against an applicant for employment or employee on the grounds of race, color, religion, sex, or National origin.

23/

See section VI A8.. (Implementation of Goals and

Timetables)

representation of black professionals in each region.

This 12% goal was established after consideration

24/

of each criteria. Blacks comprise 11.2% of the Nation-
al population and should, therefore, comprise at least
that percentage of the Department's professional work-
force. Since many minorities and women are affected
by Departmental programs and the Department has exe-
cutive responsibility for enforcing equal employment
opportunity standards externally, its own condition
must be exemplary. The higher percentage is, there-
fore, justified and should help to enhance the De-
partment's credibility while it performs its executive
functions.25/

Blacks already represent 14% of all professionals in the Department (19% in the National Office, and 10% in the Field), but are under-represented in the higher professional grades, GS-12-17.

Parity would be

24/It It is not necessary to establish the percentage goal at each grade level because of the small numbers involved. The percentage is to apply, however, to the following grade groupings: GS-5-10, 11-12, 13-15.

25/

Asst. Secretary Lovell to all State Employment Security Agencies on the subject of minority group employment in State Agencies

March 25, 1970.