achieved by upgrading Blacks in the lower prófession

al grades and by recruiting more Blacks for higher
professional slots so that they would comprise at least
12% of all employees at each professional grade level.
This redistribution would result in lessening the
number of Black professionals in the lower profession-
al grades and increasing their numerical representa-
tion at all of the higher professional grade levels.
Women should have at least 31% representation
throughout the professional ranks. They comprise 51%
of the National population, but the factor of avail-
ability limits the overall goal at this time. They
presently comprise 22.6% of all professionals in the
Department, but 66% of this number is concentrated in
the lower professional grades, GS-5-11, as compared
to 29.9% of all Departmental professionals in these

b.

grades.

Women comprise slightly over 30% of the full-time, 26/ year-round workforce,

and the fact that their

availability in some occupations of interest to the

27/

Department is limited at present

should not lower

the goal but merely lengthen the timetable.. Finally,

the Department's obligation to serve as

to serve as an equal

opportunity employer necessitates both the establish28/

ment and attainment of this goal.

C. Nonblack minorities are to comprise at least 8%

of all professional employees in and throughout the
Department's professional grade levels.
This group,

which includes Spanish-surnamed Americans, American
Indians and Orientals, comprises 7.2% of the National
population, but only 3.3% of all Departmental employ-
ees, and a mere 3.1% of all professional employees as
of March 31, 1971. Many members of this group are
directly affected by Departmental programs and poli-
cies and, therefore, deserve more representation in
the professional ranks than they have at present.

27/ See Appendix C-14 - 17; Female Representation in Occupations of Interest to DOL.

28/ White females presently comprise 20% of all white professionals in the Department, while Black females comprise 39.4% of all Black Departmental professionals.

6. Constraints

Although the exact percentage will not always be

This

achieved, a general constraint, applicable to all groups 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 29/ black employee in a particular grade grouping is not to

differ by more than one percent from that of all employees 30/

within the particular grouping.

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, and will prevent supervisors from hiring only minority females to achieve their goals.

29/The groupings will differ according to an organi

zation's grade structure; ex.

30/

GS 5-9, GS 11-13, etc.

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

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 ir

31/See Appendix A

32/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. 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

But,

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.