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ADMINISTRATION OF THE FEDERAL CONTRACT
SYSTEM AND WITHIN THE
and women with employers over which it has jurisdiction.
First, unlike the Equal Employment Opportunity Commission (EEOC), which also has jurisdiction over
of size, location, vacancy rate, higher paying jobs,
patterns of employment of minorities and women and
related factors--are in a position to make the greatest
impact on the employment problems of minorities and
The compliance review process has an added ad
vantage over complaint or charge oriented procedures
in that its primary focus is on systemic or class-wide
agencies, and labor unions who have 15 or more employ
ers and are engaged in industries affecting commerce, establishes the investigation, conciliation, and prosecu
tion of charges of discrimination as EEOC's primary
function. Only 35 percent of EEOC's charges allege class or systemic discrimination. I
An even smaller
percentage is of such comprehensiveness as to cover
an employers' total employment system as opposed to
individual segments relating to hiring, assignments,
training, promotion, etc.
Section 707 of the Civil
Rights Act of 1964, as amended, authorizes the Equal
Employment Opportunity Commission to initiate pattern
Staff Report on Investigation of Federal Enforcement of Equal Employment Opportunity Laws (hereinafter referred to as Staff Report). Prepared for the Subcommittee on Equal Opportunities of the Committee on Education and Labor, United States House of Repre
and practice charges, investigations and suits which
potentially have the same breadth as compliance re
views, other than affirmative action program issues.
In December, 1976, the Subcommittee on Equal Opportunities
reported that since the enactment of the 1972 amendments
to Title VII which authorized this procedure, fewer than
100 pattern and practice charges have been initiated, and
2 only five suits have been filed.
goals and timetables element of the obligation operates
independently of a finding of discrimination.