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Procedural Requirements

The procedural requirements of subpart C of 60-2

which contains methods, procedures, and specific tech

niques for making the affirmative action program work

toward achieving nondiscrimination and affirmative

action objectives, in some instances have proven to

be a burden to contractors and served to divert the

attention of compliance officials from "bottom line


The sheer magnitude of the examples and

illustrations tends to generate voluminous paperwork

which does not contribute substantially to the compliance determination process. Further, the examples and illustrations have the appearance of emphasizing "procedural compliance over affirmative remedies.. 6

In the ill-fated proposed revisions to 60-2 of

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the Task Force notes that the general thrust of the


Subcommittee on Equal Opportunities, Staff Report on Oversight Investigation of Federal Enforcement

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motion, upgrading, and other terms and conditions of

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tive action. Rather, such contractual obligations should be attainable without unreasonable paperwork

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at the start of the project and lay the workers off at

the completion of the project. Also, construction contractors generally move their operations as required by

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affected parties in determining the applicability of

each to a particular contract.

Conceptual problems, while the same as those en

countered in the supply and service program, are magni

fied by even more emphasis on goal achievement to the

ceater detriment of institutional changes.


difficulties also surround affirmative action require

ments which are:

inconsistently developed and applied;

not applicable to women; not applicable to all areas of

the country; and applied on a short-term basis with no

accountability for long-term results.

A description of

these problems and the existing program elements are

presented below.

Hometown Plans

In the late 1960's and early 1970's, voluntary plans

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were negotiated for each craft wishing to participate. Contractors were required only to "equitably participate" in the plan to demonstrate compliance with the Executive


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