-------
f-V U « ENVIRONMENTAL PROTECTION AGENCY
AGENCYWIDE AFFIRMATIVE ACTION PLAN
ACCOMPLISHMENT REPORT
FY 1984
*"" *
Form 504: Accomplishment Report of Affirmative Action for Minorities
and Women
t,.
"" Form 505: Summmary Sheet, FY 83 - FY 84 Change in Work Force EEO
Profile by PATCO
Form 506: FY 83 - FY 84 Change in Work Force EEO Profile
by Pay Level, pp. 1-3
Form 507: Summary Sheet, Distribution of EEO Groups and Under-
representation Indices by PATCO and Pay Level, pp. 1-2
Form 508: Summary Sheet, FY 84 Hiring Goal Accomplishments by PATCO
Form 509:' Summary Sheet, FY 84 Internal Movement Goal Accomplish-
ments by PATCO
Form 510: Barrier Elimination, pp. 1-6
ANNUAL UPDATE
FY 1985
Form 511: FY 85 Annual Update of Affirmative Action Program for
Minorities and Women
Form 512: Summary Sheet, FY 85 Hiring Goals by PATCO
Form 513: Summary Sheet, FY 85 Internal Movement Goals by PATCO
Form 514: Projected Barrier Elimination, pp. 1-5
NARRATIVE STATEMENT, pp. 1-4
STATEMENT OF ACCOUNTABILITY
" CERTIFICATION OF QUALIFICATIONS OF PRINCIPAL EEO OFFICIALS
ATTACHMENTS:
Memo: EPA's Affirmative Action Plan for 1985
Memo: Development of 1985 Affirmative Action Plan
Memo: Guidance and Instructions for Development of Affirmative
Action Plan
Memo: Affirmative Action Goals for FY 1985
List of EPA Planning and Reporting Units
U.S. Environmental P-"it~"*,lon Agency
Librarv. Room 2*01 PM--211-A
401 M Street, S.W.
Washington, DC 20460
-------
FY« 4ACCOMPUSHMENT REPORT OF AFFIRMATIVE
ACTION FOR MINORITIES AND WOMEN
. P/M UNIT
.COMMAND
.COMPONENT
lOKNCV
of
Component or P/fl tfn/f
A**pon*/0fo
OttictH:
Environmental Protect ion Agency
William D. Ruckelshaus, Administrator
(Name end title)
401 M Street S.W. (A-100) '
(Address)
Washington, D.C. 20460
382-4700
(Telephone number commercial or FT5)
JAN 31985
(Signature of the responsible official)
(Date)
Humbor el
Unit$ (r*port« «f» x tn not
Numbor of Conwuntfs/CompoMnf * faggrtgct* rvports tn«crt»tf, /f
SELECTED AQENCY FY 9 STATISTICS: .
^^ SES ADtED,FX,ST
MumoarofM>p/oy««*«o^inniflgo/fWorryMr* 9810' 198 24 '85
Nun&tr of mp/oy**s « ntf of ivport yMr
Wamotr of «np/oy««s topvMMT from ffto - Ebtperts appointed under 5 U.S.C. 3109
EX - Executive Level, Federal Executive Salary Act of 1964
ST - Scientific and Professional, 10 U.S.C. 1581
CC - Gcranissioned Corps, Public Health Service
NAME Or PBMSON ««0
Cecelia F. Scott
MEPOftT
TVUK'MONC
382-4564
EEOC roMM 504
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BARRIER ELIMINATION
ftKPOKT «Yi
I»/R UNIT
COMMAND
COMPONENT
AGENCY
1. Number of Barriers Identified for Antlytls and Elimination In FY 64:.
2. Number of these Barriers Eliminated In FY 84: 1
3. Number of these Barriers Partially Eliminated In FY ff 4,
For each barrier addressed during the reporting year, Indicate the occupations from which II tended to exclude people,
whom it tended to exclude, and how the barrier was eliminated or partially eliminated (that to. what alternative procedures
were Instituted to replace the barrier). Where the barrier was not eliminated, please explain what prevented Its elimination:
Barrier No. 1:
r
See attached sheets.
Barrier No. 2:
Form 510-1
-------
BARRIER ELIMINATION
Barrier At LACK OF CLEARLY DEFINED RESPONSIBILITIES,
OBJECTIVES AND ACCOUNTABILITY OF MANAGERS AND
SUPERVISORS FOR AFFIRMATIVE ACTION
This barrier was partially eliminated in FY 84. A few items
were not completed.
1. EPA policy statements on EEO and Affirmative
Action have been issued in FY 84 and early
in FY 85.
2. Nemos confirming specific goals and the account-
ability of each Assistant Administrator (AA) and
Regional Administrator (RA) were issued both
in FY 84 and FY 85.
3. The Deputy Administrator issued a memorandum on
performance management requiring that each super-
visor and manager have measures related to EEO
and Affirmative Action incorporated into their
standards for human resources management in
their performance agreements. In addition, the
Deputy required each Agency component that did not.
meet its goals, to provide a rationale in writing to
the Deputy Administrator indicating why it did not
meet its goals. This approach was determined to be
more appropriate and effective than one requiring
each supervisor and manager to identify EEO accom-
plishments as a critical job element.
4. A comprehensive EEO training program was
developed between PMD and OCR and a pilot
project was tested during FY84. The Agency
plans to expand this training in an effort
to reach all supervisors and managers during
FY 85.
5. OCR established an Affirmative Action Tracking
Report as an aid in self-monitoring for meeting
affirmative action goals. This report was
issued bimonthly to all Agency components along
with a progress summary and a listing of organi-
zations in rank order of their affirmative action
Form 510-2
-------
accomplishments. These provided an incentive
for achieving goals and an effective means
of monitoring change in our workforce*
6. Revision of the EEO Manual stating specific
responsibilities of managers and supervisors
was initiated in 1984 and will be completed
in 1985.
Barrier B; LACK OF SUFFICIENT TRAINED STAFF IN EEO
AND PERSONNEL TO FACILITATE EFFECTIVE
RECRUITMENT
This barrier was partially eliminated.
1. OCR conducted an Affirmative Action Training
Conference in November 1983, and determined
that a "follow-up conference during FY 84 was
not necessary. In addition technical assis-
tance was provided to the Regions by phone,
and a training session was conducted for the
members of the Headquarters Administrative
Management Council which involved them in
Affirmative Action planning for the first
time. Specific guidance and instructions
to both Headquarters and field offices
were provided in raemos attached to this
plan.
2. Training conferences held for Hispanic
Employment Program Managers (HEPMs) and
Federal Women's Program Managers (FWPMs)
during FY 84 emphasized the role of Special
Emphasis Programs in planning, monitoring
and recruitment activities of the Affirmative
Action Program. This activity will be
expanded to provide training for Black
Employment Program Managers (BEPMs) in FY 85.
3. No formal cross-training for EEO and
personnel officials in staffing and recruit
ment occurred in FY 84 although informal
interchange took place through joint recruit-
ment efforts. This area will receive increased
emphasis in FY 85.
Form 510-3
-------
Barrier C; INADEQUATE COMMUNICATION AND COORDINATION
AMONG EEO, PERSONNEL, AND PROGRAM STAFF
IN RECRUITMENT EFFORTS
«£ - . . .
This barrier was eliminated in FY 84 through concerted effort by
Personnel and Civil Rights staff.
1. The Directors of Personnel Management and
Civil Rights issued joint memos concerning
recruitment activities and other affirmative
action matters.
2. Key staff from Personnel, Civil Rights and
program offices met to develop information
on vacancies, strategies and coordination in
recruitment activities.
3. Information and reports are being shared
regularly at Headquarters between Civil
Rights and Personnel and communication is
improving in the field.
4. The establishment of an automated applicant
referral system has assisted Personnel,
Civil Rights, and program office staff in
working together to match qualified female
and minority applicants with job vacancies.
5. The Office of Civil Rights conducted an
Affirmative Action Training Conference for
both EEO and and Personnel staff responsible
for Affirmative Action planning early in
FY 84 to promote close coordination, joint
planning and implementation of all aspects
of affirmative action including recruitment
activities.
6. Personnel and Civil Rights staff both at
Headquarters and Region II worked closely
together to plan and implement a very
successful recruitment trip in Puerto Rico
; where over 30 job offers were made to
Hispanic students. This joint effort
received formal recognition in an Agency
;' award and has served as the impetus and
" model for a similar effort in FY 85 focused
upon recruitment of Blacks.
Form 510-4
-------
A report on Affirmative Action accomplish-
ments during 1984 and proposed plans for
1985 was presented to the Deputy Administrator
jointly by the Office of Civil Rights and
Personnel.
Barrier Dt LACK OF TRAINING AND DEVELOPMENTAL OPPORTUNITIES
FOR WOMEN AND MINORITIES TO ADVANCE WITHIN THE
AGENCY a) UPWARD AND OUT OF CLERICAL SERIES and
b) UPWARD WITHIN PROFESSIONAL SCIENTIFIC AND
TECHNICAL FIELDS
This barrier was partially eliminated in FY 84. Three planned
actions were begun but not completed. A fourth action is a major
new initiative for the Agency.
1. The Professional Development Plan proposed by
Women in Science and Engineering at EPA has
been adopted and incorporated into the planning
of the Office of Human Resources Management.
Implementation will begin in FY 85 with the
creation of a Scientific and Technical Career
Advisory Committee.
2. Commitment to an aggressive Upward Mobility
Program was confirmed by Agency leadership
and revision of program guidance was under-
taken by Personnel. Final guidance is being
issued early in FY 85.
3. Development of two English language courses
to help non-native English-speaking employees
improve their command of American English.
"Mastering American English" is a course to
improve writing skills and "English Language
Skills" is a conversational course. These
courses were offered to all employees, but
aimed at meeting the needs of the newly-
hired engineers from Puerto Rico. The con-
.versational course will continue through
early FY 85. .
4. The establishment of an Office of Human
Resources Management (OHRM) at EPA during
FY 84 emphasizes the high priority of this
issue within EPA. It marks the beginning
Form 510-5
-------
of on-going long range efforts to address the
current deficiency in training and developmental
opportunities for all employees. The Office is
currently working on the formation of an Agency-
wide Human Resources Council to strengthen com-
munication and advise the Office in development
of policies, strategies and programs for workforce
development and management. The first major step
was an Agencywide planning conference held early in
FY 85. Several specific projects are just getting
under way. The Office of Civil Rights will work
closely with OHRM to assure that planning takes
into account the special needs of women and
minorities to assure their equitable participation
in the training and development programs of the
Agency.
Barrier E; LIMITED USE OF CREATIVE STAFFING TECHNIQUES
We were unable to formally address this barrier during the
fiscal year, but through informal contacts, the OCR staff
have provided suggestions and ideas on creative staffing
techniques to agency managers and supervisors. In addition,
we initiated several activities which we plan to continue
and expand in FY 85:
1. Increased use of direct hire authorities
for Engineers and Environmental Protection
Specialists in light of recent recruitment
successes at the University of Puerto Rico
and in preparation for the FY 85 targeted
recruitment for Black professionals in
science and engineering.
2. Development and coordination of more exten-
sive use of the cooperative education
program.
3. Increased use of temporary direct hire
appointments.
4. Increased use of Intergovernmental Personnel
Act (IPA) exchanges in order to establish
closer ties and recruitment efforts with
predominantly minority institutions.
5. Increased use of the Junior Fellowship Program
to bring minorities and women on board and to
assist in developing their professional'
potential.
Form 510-6
-------
I FY 8 5 ANNUAL UPDATE OF AFFIRMATIVE ACTION
PROGRAM FOR MINORITIES AND WOMEN
Kama ef Reporting
Agancy, Command*
ComoaiMit w Pl/R Unit: .-> .... . .
taNnpeiwuoTivHunii. environmental Protection Agency
P/M UNIT
_«_. COMMAND
COUPON KMT
A AOKMCV
Responsible
Agency Official: William D. Ruckelshaus, Administrator
{Atone ana* Jirt*>
401 M Street S.W. (A-100)
(Addrett)
Washington, D.C. 20460
382-4700
(Telephone Number Comnmeo/ or
fot&J&sZL&z**--'
(Signature of the Responsible Official)
NumlMur of Planning/Raporttnfl Unit* A 345 T 74 c 304 o 3 Total _
/
NAMK Or »*B»A*EN OP MKPOMT
Cecelia F. Scott
FTS^
JAN 3 1985
(Date)
1
_
1315
382-4564
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PROJECTED BARRIER ELIMINATION
UPDATE BY:
___ *fm UNIT
_COMMAND
__ _ _ COMPONENT
~ ~ ~~ AGENCY
1. Number of barriers to be addressed in plan year: 6
2. Describe each barrier, the occupations It tends to exclude people from, whom it tends to exclude, and how It wilt
be addressed:
*. During FY85, ife plan to resolve the four barriers which
in FY84. In addition, we have ldt>ntifiaA «-un no,., ^-,rr^
See attached pages. _
at-f-fnii Oi
-------
I
A. LACK OP CLEARLY DEFINED RESPONSIBILITIES, OBJECTIVES AND
ACCOUNTABILITY OF MANAGERS AND SUPERVISORS FOR AFFIRMATIVE
ACTION.
ACTION TAKEN OR PROPOSED:
1. The Director of Civil Rights has issued a memo-
randum outlining the Office of Civil Rights Plan
for FY 85 including objectives, activities and
general resource requirements for support of
Affirmative Action.
2. The specific responsibilities of managers and
supervisors as well as those of EEO staff and
Personnel will be included in a revised EEO
Manual to be issued later in this year.
3. A comprehensive EEO training program for super-
visors and managers will be implemented during
FY 85, an expansion of the pilot EEO training
conducted in FY 84.
B. LACK OF SUFFICIENT TRAINED STAFF IN EEO AND PERSONNEL TO
FACILITATE EFFECTIVE RECRUITMENT
1. During FY 85 OCR will sponsor a follow-up affir-
mative action conference to train EEO and
Personnel Staff.
2. OCR will conduct training activities for EEO
Officers and other EPA personnel with responsi-
bilities in EEO and Affirmative Action.
3. The OCR and PMD will cross-train EEO and
Personnel staff in staffing and recruitment
programs.
C. LACK OF TRAINING AND DEVELOPMENTAL OPPORTUNITIES FOR
WOMEN AND MINORITIES TO ADVANCE WITHIN THE AGENCY a)
UPWARD AND OUT OF CLERICAL SERIES AND b) UPWARD WITHIN
PROFESSIONAL SCIENTIFIC AND TECHNICAL FIELDS
1. The OCR will follow through with the Office of
Human Resource Management (OHRM) to ensure that
OHRM includes the Professional Development Plan
Form 514-2
-------
in their FY 85 activities. This plan is intended
to support effective employee career development
related to EPA's environmental mission.
Personnel and OCR will work with program offices
to develop creative on-the-job training through
intern programs, rotational assignments/ details,
structured mentoring programs, etc., as well as
formal course training at EPA, OPM, and elsewhere,
D. LIMITED USE OF CREATIVE STAFFING TECHNIQUES
ACTION TAKEN OR PROPOSED:
1. OCR and Personnel will conduct cross-training
of their staffs, as needed, to update their
knowledge and assure consistency in guidance to
managers.
2. OCR will work with Personnel to develop infor-
mation materials describing various staffing
techniques for use by managers and supervisors
in considering options for filling vacancies.
3. OCR EEO staff will work with Personnel to identify
vacancies which can be filled with non-status
applicants thereby opening additional employment
opportunities for minorities and women.
4. Personnel will work with appropriate program staff
to explore all staffing options, including restruc-
ture of jobs, use of co-op students, etc., prior to
publishing vacancy announcements.
E. INSUFFICIENT TINE ALLOTTED BY MANAGERS AND SUPERVISORS FOR
COLLATERAL DUTY EEO PERSONNEL TO PERFORM EEO DUTIES
Over the past several years, the Special Emphasis
Program (SEP) Managers in EPA have performed their collateral
EEO duties with minimum guidance from Headquarters because of
a shortage of resources at Headquarters. In addition, there
are several SEP Manager postions which remain vacant throughout
the Agency. Managers received more technical assistance and
guidance from Headquarters, but many of them are still not able
Form 514-3
-------
to devote a specific amount of fixed time to collateral duty
EEO responsibilities.
ACTION TAKEN OR PROPOSED:
1. Strong communications linkages in the SEP have been
established. Collateral duty SEPM's are now receiving
more frequent and comprehensive guidance and technical
assistance from the National level.
2. We expanded the National SEP Managers at Heaquarters
to include a National Black Employment Program
Manager.
3. We intend to finalize a memorandum of understanding
between each SEP Manager and supervisor spelling out,
in detail, the agreement in performing collateral EEO
duties.
4. OCR officials will encourage establishment of SEP
managers and programs where no programs currently
exist.
5. National SEPM's will publish a general guidance
document to aid field SEPM's in developing and con-
ducting effective programs in each field -location.
6. Yearly training meetings for each SEP group have
been scheduled to provide training on analysis and
documentation of issues, affirmative action respon-
sibilities, work plans, budget development, and
general public relations with agency officials in
local and field installations, etc.
F. INABLILITY TO REACH QUALIFIED NON-STATUS APPLICANTS
Blocked or closed Office of Personnel Management (OPM)
registers prevent prospective applicants from getting onto
registers and prevents EPA Officials from selecting and/or
certifying applicants. This has an adverse impact on minority
and female candidates if they are not currently employed by
the Federal government.
Form 514-4
-------
ACTION TAKEN OR PROPOSED!
1. OCR will work with the Director of the Personnel
Management Division to develop a written inquiry as
to the status of OPM registers throughout the country.
2. OCR officials will prepare a request from EPA*s top
management official to OPM officials requesting that
entry level professional and administrative registers
be purged, updated, and opened for a specific period
of time on a yearly basis. This allows for wider,
more diverse applicant pools including minorities and
women in the registers.
3. If OPM does not agree to purge and update these
registers, OCR will encourage EPA officials to seek
authority from OPM to develop our own special examining
unit for scientists, biologists, and chemists.
4. EPA officials in each Region will also work closely
with OPM officials in their Region to resolve our
problem with blocked or closed registers.
Form 514-5
-------
NARRATIVE STATEMENT - EPA .AGENCYWIDE
1984 ACCOMPLISHMENT REPORT
During FY 1984, EPA developed a comprehensive agencywide
strategy in establishing and pursuing its Affirmative Action
goals. This strategy represents an important change from the
unit-by-unit approach followed in previous years. We sought
to improve representation of women and minorities in our work-
force agencywide by starting with the profile of the Agency
as a whole and developing goals designed to improve agencywide
representation of each underrepresented group in comparison
with the national civilian labor force. He placed emphasis
upon the Professional and Administrative categories of jobs
since these were the areas in which the Agency had the
greatest number of opportunities for hiring and also the
poorest representation of women and minorities. Goals were
assigned primarily on the basis of available opportunities
for hiring, taking into account, but not exclusively reflect-
ing, the relative levels of representation in particular
Planning and Reporting (P/R) Units. For example, a Regional
Office with large numbers of projected vacancies was assigned
higher numbers to be targeted for affirmative action than a
Region with fewer vacancies, even if its current status of
representation of target groups might be better than the
others. We did not reduce or redistribute goals orginally
set by P/R Units, but rather targeted additional slots for
specific groups, as needed, to assist the Agency as a whole
to show improvement in their percentage representation.
EPA achieved considerable success in meeting its 1984
goals; women and minorities comprised 47% of all permanent
hires in the professional and administrative (P&A) categories.
Furthermore 56% of the net gain in the P&A categories was
comprised of women and minorities. The actual percentage of
women and minorities in the Agency's P&A work force improved
by 2.5 points. This is an excellent first step toward closing
the 20 point gap between where the Agency started at the end
of FY 83 and where it should be based on the national civilian
labor force reported in the 1980 census. To reduce the
remaining gap our 1985 plan continues affirmative action at
EPA at a comparable level to 1984 while the Agency remains in
a hiring mode.
EPA exhibited at numerous conferences during the past
year and undertook targeted recruitment designed to reach
qualified women and minorities for scientific and engineering
positions. The highlight of this activity was a recruitment
-------
- 2 -
effort in Puerto Rico where the Agency made job offers on the
spot to over thirty Hispanic engineers, 23% of whom were women.
This project has served a a model for 1985 initiative focusing
on recruitment of Blacks as well as Hispanics.
The establishment of an automated Agencywide referral
system provided a bank of applications for managers across
the Agency. This system is still being refined and we (
anticipate greater use of it in 1985. .
To assure accountability we developed an Affirmative
Action Tracking Report as a mechanism for monitoring progress
in improving representation of women and minorities in our
workforce. This was issued bimonthly to top managers. At
the close of the year, Agency components which did not meet
their goals were required to submit the rationale for their
shortfall to the Deputy Administrator. We plan to continue
these measures for assuring accountability in 1985.
1985 UPDATE
In 1985 EPA will continue to build upon its 1984 Agency-
wide approach with focus on hiring opportunities in the
Professional and Administrative (P&A) job categories. As a
matter of Agency policy, each major Agency component was
asked to target a minimum of 52% of its projected P&A vacancies
for affirmative action. Each P/R Unit has thus developed
goals at a level of 52% or better consistent with improving
its own work force profile as well as improving representa-
tion of women and minorities in the Agency as a whole*
In addition to continuing last year's effort, EPA is
undertaking four new initiatives in 1985:
1. The Upward Mobility Program has been revised
and each Agency component has been asked to
set aside positions for Upward Mobility slots,
so that 1% of the Agency's total permanent
positions are committed to the Upward
Mobility Program.
2. Each Headquarters component has been asked to
establish affirmative action goals in hiring
temporary and term employees since these
employees form a pool of applicants for later
conversion to permanent status. They con-
stitute about 12% of the Headquarters P&A
workforce.
-------
- 3 -
3. The agency is undertaking a major targeted
recruitment effort focused upon the
Historically Black Colleges and Universities
to locate qualified Black candidates for
scientific and engineering positions at EPA.
This effort is modeled after the. 1984 Puerto
Rican recruitment activity.
4. We will be closely monitoring the hiring and
promotion of women and minorities into the
upper grade levels by tracking progress to
encourage improved representation of women
and minorites in Grades 13-15.
Goals have been established for some target groups where
analysis of representation in a particular PATCO category
indicates full representation. These goals have been set in
specific job series and/or grade levels where the target group
is in fact underrepresented. For example, while Black males
are fully represented in the general "professional category"
our plan includes goals for Black males in environmental
engineering where they are severely underrepresented.
Explanatory Notes on Specific Forms
The distinction between "external hiring" and "internal
movemertt" based on the Equal Employment Opportunity Commission
(EEOC) definition continues to be problematic at EPA. We do
not have the capability to differentiate between them in our
current data systems. Further, the distinction based on
EEOC's definition is not useful to EPA management in planning
or in tracking progress. Form 508, Summary Sheet of Hiring
Goal Accomplishments thus reflects hiring of persons from out-
side EPA but not necessarily from outside the Federal Government,
Form 509, Summary Sheet of Internal Movement Goals Accomplish-
ments, includes a mix of information, based primarily on
movement within EPA and includes formal Upward Mobility
Program achievements as well as promotional activity. At the
Agency level the form shows promotions into grades 5, 9, 13,
and SES, since this was the only data available showing
significant upward movement.
In determining the underpresentation indices (UI) for
each target group included on Form 507, Summary Sheet of
Distribution of EEO Groups and Underrepresentation Indices by
PATCO and Pay Level, we frequently were required to use the
undifferentiated CLF data. We have shown this by use of an
asterisk wherever the UI is based on the CLF rather than the
differentiated data.
-------
- 4 -
Data for the end of FY 1983 shown on Forms 505 and 506,
Change in Work Force EEO Profile by PATCO, and by Pay.Level,
has been changed from the previous Accomplishment Report
submitted to EBOC. The changes reflect corrections in PATCO
codes and the inclusion of some personnel actions taken prior
to September 30, 1983 but not entered into the data system in
time for the original submission.
-------
STATEMENT OF ACCOUNTABILITY
EPA assures accountability in Affirmative Action through
three principal means:
1. A new policy statement will be issued indicating
continued commitment and expectations of the new
Administrator regarding Affirmative Action and
Equal Employment Opportunity.
2. The Deputy Administrator has directed that a
standard on resource management incorporating
performance in EEO responsibilities be included
in every manager's and supervisor*s performance
agreement. Specific measures based on Affirmative
Action commitments are being developed for
individual managers and supervisors within the
Agency's components.
3. The Office of Civil Rights has developed a tracking
system and will issue reports quarterly on progress
in meeting Affirmative Action goals. These will be
based on information submitted by the individual
Agency components matched with data from computer
reports*
-------
CERTIFICATION OF QUALIFICATIONS OF PRINCIPAL EEO OFFICIALS
X certify that the qualifications of all officials, full-time
and part-time, concerned with administration of the EEO Program,
including the following:
Director, Office of Civil Rights
Equal Employment Opportunity Officers
Federal Women's Program Managers
Hispanic Employment Program Managers
Black Employment Program Managers
EEO Counselors
Other EEO Staff Officials
both at Headquarters and Field Installations
have been reviewed by competent authority and the incumbents of
these positions neet the standard outlined in Qualifications
-Standards Handbook X-118 under "Equal Opportunity Specialist
GS-260" or "Qualifications Guide for Collateral Assignments
involving Equal Employment Opportunity Duties." Evidence that
the review has been made and its findings are on file and avail-
able for review by EEOC officials.
I further certify that provisions of FPM Letter 713-36, Documenting
EEO Collaterial Duties in Official Position Descriptions have been
net.
Date
-------
SB)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OCT 5384
OFFICE OF
TNI AOMIMKTBATO*
MEMORANDUM
SUBJECT :
FROM i
TO !
EPA's Affirmative Action Plan for 1985
Alvin L. Aim
Deputy Administrator
Assistant Administrators
General Counsel
Inspector General
, Regional Administrators
Staff Office Directors
Laboratory Directors
The primary objective of our 1984 Affirmative Action Plan (AAP)
was to aggressively recruit and hire highly qualified women and
minorities to improve their overall representation in our workforce.
The Directors of Civil Rights and Personnel Management Division tell
me that we will accomplish that objective. Let me express my sincere
appreciation for your efforts. I will personally acknowledge those
of you who met or exceeded your 1984 goals and, as I indicated in my
August 20 memo, I will closely review the rationale for those of you
who did not meet them.
I recognize that you are engaged in substantial hiring very
early in the fiscal year. I expect you to be mindful of your respon-
sibility in meeting your Affirmative Action commitments in recruiting
and hiring from the start.
Based on this year's performance, we demonstrated our ability
to locate and attract significant numbers of qualified women and
minorities to the EPA workforce. As of September 5, the total
number of new hires for 1984 was 975 of which 47% are women and
minorities. This means that we met over 90% of the goal which we
established a noteworthy achievement considering that the goals
were not in place until the beginning of the second quarter, and we
have been under restricted hiring authority for the past two months.
One of our major successes in 1984 was the targeted recruitment
program conducted in Puerto Rico under Herb Barrack, Assistant Regional
Administrator in Region II. Through his efforts we were able to make
firm job offers to over thirty Hispanic engineers on the spot which
led to improvement in the overall representation of Hispanics in our
-------
- 2 -
workforce. In addition to continuing this recruitment effort in 1985,
I have asked Mr. Barrack to initiate a targeted recruitment effort for'
Black engineers and scientists. Accordingly, I want each of you to
designate a lead person, with authority to make personnel commitments
for you, to work with Mr. Barrack and the Directors of Civil Rights
and Personnel Management to implement this high priority effort. You
should submit the name of your designee to Herb Barrack (FTS 264*2520)
and Nat Scurry (FTS 382-4575) by the end of this month.
In addition to maintaining this strong focus on hiring in 1985,
we will also concentrate on the following:
1. Increasing the Representation of Women and Minorities
in the Higher Grades and in Management PositmnsT
Our employment profile shows that of the 11,315 permanent full-
time and permanent part-time employees at EPA, approximately 41% are
female and 19% are minorities (male and 'female). Women and minorities
comprise 89% of all employees in grades GS 1-8 but only 22% at .the
GS/GM 13-SES levels, and very few are in management positions. For
FY 1985, it is the goal of EPA to increase the representation of
women and minorities in the upper grades and in managerial positions. .
You may achieve this goal through promotion of qualified women
and minorities already at EPA and through new hires. In your 1985
hiring you should ensure that women and minorities -comprise at least
the same share of those hired in grades 13 and above as in the over-
all hires. In addition, we need to foster the development of talented
women and minorities within our ranks. The new Office of Human
Resources Management, under the direction of Kirke Harper, has
responsibility and the staff expertise to provide you assistance in
developing EPA's human resources.
2. Reinstituting an Agencywide Upward Mobility Program
A long term means of increasing the number of women and minor-
ities in mid and upper level positions is through the Upward Mobility
Program. Through Upward Mobility, EPA can take advantage of the
skills and knowledge of employees now confined to low grade positions
who have potential to assume more challenging responsibilities in
new career fields. The Personnel Management Division (PMD) will
manage and issue updated guidance on this program by mid-November.
Meanwhile, you should begin to identify Upward Mobility positions
and training as part of your FY 1985 planning process. I would
expect each AAship, Regional Office, Laboratory and Staff Office to
set aside 1% of its positions for this purpose.
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- 3 -
3« Applying Affirmative Action in Hiring Temporary and Term
Employees
The Affirmative Action Plan (AAP), required by the Equal
Employment Opportunity Commission, covers only permanent full-time
and permanent part-time employees. However, a significant number of
EPA employees (about 2,200) have temporary or term appointments.
EPA will, as a matter of policy, apply the same affirmative action
principles to persons hired on such appointments. There are two
reasons. First, temporary and term employees, because of their
hands-on experience at the Agency, comprise an important pool from
which we often select candidates for permanent employment* Second,
women and minorities on temporary and term appointments are clustered
in the lowest grades to an even greater extent than those in permanent
positions. At Headquarters, where over 12% of our professional and
administrative (P & A) workforce are temporary or term employees,
specific goals will be established in this area by each office.
4. Maintaining Affirmative Action Progress in the Event of
Changing Hiring Projections
Affirmative Action hiring goals are based on projected vacan-
cies for the entire year (new positions and positions arising from
attrition). The goals are defined in terms of filling a percentage
of those vacancies with women and minorities a percentage based
on the composition of the civilian labor force. I have determined
that the percentages used in establishing goals for the Plan will
be held constant, whether the actual number of projected vacancies
decreases or increases.
5. Emphasizing Managerial Accountability
As was the case last year, EPA will aim to fill no less than
52% of all vacancies in P&A job categories with women and minor-
ities. All senior managers will be held accountable for EEO/
Affirmative Action results in their organization. In addition to
monitoring your progress in meeting the 52% hiring goals, I will
also monitor progress in increasing upward mobility participation
based on the goals which you, working with PMD, will set for your
organizations. In an effort to reach our equal employment opport-
unity (EEO) goals, I am requiring that the EEO/Affirmative Action
responsibilities, including progress in meeting, assigned goals, be
specifically addressed as a performance standard for each agency
manager and supervisor.
I would like you to work with the Office of Civil Rights (OCR)
to produce and implement a 1985 Plan which is consistent with the
policy directives I have outlined above. While OCR is responsible
for pulling together the final Agency product, I expect that the
1985 plan, more than ever, will be truly a collaborative effort.
OCR will soon be sending you implementing guidance for preparation
of the PY 85 AAP. I appreciate your cooperation in planning and
carrying out an effective Affirmative Action Program at EPA.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington. D.C. 20460
OFFICE OF
CIVIL RIGHTS
OCT 4 1984
MEMORANDUM
SUBJECT: Development of 1985 Affirmative Action Plan
FROM i Nathaniel Scurry, Director f/d, )fivUMvL*~
Office of Civil Rights ' Q
TO : Assistant Administrators
General Counsel
Inspector General
Regional Administrators
Staff Office Directors
Laboratory Directors
You will shortly receive the Deputy Administrator's memorandum
of October 4 establishing EPA's policy regarding our Affirmative
Action Plan (AAP) for 1985. 'You will note that its content is
essentially unchanged from the draft sent out for your comment in
August, and confirms both the direction and level of effort we
began in 1984. This memo provides you with the schedule for imple-
menting Mr. Aim's policy guidance in development of our 1985 AAP.
As you know EPA is required to submit its AAP to the Equal
Employment Opportunity Commission (EEOC) by December 31, 1984 for
review and approval. Last year EEOC granted EPA a three-month
extension to submit our AAP, but has indicated that it expects our
AAP on time this year.
In order to meet that deadline while focusing on the substan-
tive portion of the AAP, i.e. working to achieve our goal through
early hiring this fall, we will develop our AAP by first determining
our specific goals and then developing the complete plans with all
the documents required by EEOC. We will conduct this two-stage
operation in adherence to the attached timetable.
'To assist you in development of your affirmative action goals
and plans we are providing detailed guidance as well as comprehensive
workforce data reports to key staff in your office. At Headquarters,
my staff met with the Administrative Management Council on October 4th
to brief representatives of each Headquarters office on steps necessary
to develop the goals and the subsequent Headquarters Plan whose
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-2-
preparation will be coordinated by the Office of Civil Rights. For
the field my staff is sending specific instructions to the Regional
Directors of Civil Rights and Regional and Area EEO Officers for
development of the AAP and completion of the documents required
for submission to the EEOC. In addition, Special Emphasis Program
Managers can be a useful resource in developing goals and overall
plans* as well as in recruiting qualified minorities and women for
available positions.
With this assistance I think you will be able to meet the
deadlines. While they are tight, I am sure you can appreciate
that they are essential to submission of our AAP to EEOC by
December 31. . -
*
Please contact me or Cecelia Scott, Team Leader for Affirma-
tive Action and Special Emphasis Programs, at PTS 382-4564 if you
have questions or need further information. Thank you for your
cooperation in developing and carrying out an effective affirmative
action program at EPA.
4
Attachment
Schedule for Developing 1965 Affirmative Action Plan.
cc: Deputy Administrator
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SCHEDULE FXJB TCVEWmUfT OF 1985 AFFIRMftTIVE ACTION PLAN tAAP)
DATC
October 19
PROJECT
Dissemination of workforce
data reports to Headquarters
Offices, Regions, and Labs
MHO IS RESPONSIBLE
Information Services Division
and OCR
October 22
October 25
November 8
November IS
November 21
dcventer 21-30
Wwcnber 30
ur 7
December 14
DBceafcer 31
Submission of projected
vacancies and proposed
affirmative action goals
to Office of Civil Rights (OCR)
Initial Progress Report to
Deputy Administrator (DA)
* Submission of report to DA
with rationale for failure
to meet py 84 goals
rotation on distribution
He
of goals to Headquarters
Offices, Regions and Lahs
Progress Report to DA
* submission of final goals
to CO
Progress Report to DA
* submission of complete AAP
to OCR
Completion of Headquarters AAP
Briefing on AAP progress and
outstanding issues for DA
Resolution of outstanding issues
progress Report to DA
Final Progress Report to DA
Progress Update to Headquarters
Offices, Regions, and Labs
Submission of recommendations
on individual AAPs to Regions
and Labs
Submission of Agency and Head-
quarters AAPs to Adninistrator/DA
* Submission of all AAPs to REOC
following notice of approval
by Administrator
Assistant Administrators
General Counsel
Inspector General
Regional Administrators
Staff Office Directors
Laboratory Directors
(with copy to Area
EH) officers)
OCR
Regions. Labs, and Headquarters
Offices that (lid not meet
percentage goals in 1984
OCR
OCR
Assistant Administrators
General Counsel
Inspector General
Staff Office Directors
OCR
Regional Administrators
Area EEO officers
OCR
OCR
OCR/appropriate senior
managers, DA as necessary
OCR
OCR
OCR
OCR
OCR
Regional Administrators
Area BED Officers
OCR
Documents requiring signature
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
OFFICE OF
CIVIL RIGHTS
OCT
MEMORANDUM
SUBJECT:
Guidance and Instructi
Affirmative
sEbr Development of
^
FROM
TO
: Cecelia Scott(_
Team Leader for Affirmative Action and Special Emphasis
Programs
« Office of Civil Rights
: Regional Directors of Civil Rights
Area EEO Officers
This memo provides specific guidance and instructions for
developing our Affirmative Action Plan (AAP), based on EPA's 1985
affirmative action policy established by the Deputy Administrator
and the implementation schedule outlined by the Director of
Civil Rights in his October 4 memo. It includes some general
information on preparation of our plans as well as specific
instructions for completing the forms required for submission
to the Equal Employment Opportunity Commission (EEOC). In
addition I have attached several items to assist you in develop-
ing your AAP and in briefing managers on our objectives for the
1985 affirmative action program.
General Information
He will develop our AAP in two stages: 1) Development of
goals and 2) Development of AAP documents for EEOC. Two dates
are critical for submission of documents to the Office of Civil
Rights (OCR) in order to ensure timely development of both Agency-
wide and individual component plans:
October 22 - Submission of projected vacancies and
proposed affirmative action goals
November 15 -. Submission of complete AAP for each lo-
cation as required by EEOC Management
Directive 707A
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Please let us know whom you designate as the lead
person to coordinate the development of your AAP and to act
as liaison with OCR.
The Special Emphasis Program Managers have an important role
to play in advising managers, developing goals and identifying
barriers, as well as in outreach and recruitment to help
managers locate qualified minorities and women to meet AAP
objectives. They, as well as Program Managers, Personnel and
other EEC staff should be actively involved in the entire
development and implementation of the AAP.
Development of Goals
Early agreement on our goals .is essential to assure appro-
priate focus in our recruitment and hiring activities early this
fiscal year. You should submit EEOC forms 512 and 513 for this
purpose by October 22, listing: a) the total number of projected
vacancies in each PATCO category under "PLANNED t", b) the total
number of proposed affirmative action goals under "TOTAL* - "ALL",
and c) the appropriate distribution of goals under the specific
target group headings. Form 512 is used to show hiring goals;
Form 513 should be used to show internal movement goals such as
anticipated promotion actions. Projected vacancies and.goals
from these two forms combine to represent the overall proposed
affirmative action commitment of your Region .or location* OCR will
review your proposed goals to ensure consistency with Agency
policy and with overall objectives to improve representation
for each underrepresented target group. We will notify you
of our recommendation by November 1.
Development of AAP Documents
Since the Accomplishment Report portion of the AAP and part of
the Update can be developed independently of the goals, preparation
of the workforce analysis can begin as soon as you receive the new
Civil Rights computer reports with September 29 data. My memo of
October 2, 1984 describes these more fully. I have also
referenced below the appropriate data reports which may be
used to complete each EEOC Form in the Accomplishment Report.
For purposes of MD 707A, Headquarters, each Regional Office
and each composite of laboratories serviced by an Area EEO Office
will be considered a Planning/Reporting (P/R) Unit. Certain modi-
fications may be made in reports submitted by the Area EEO Offices
in order to reflect the diverse locations of the small laboratories,
pending agreement with Headquarters OCR.
By November 15, 1984 each P/R Unit will submit its completed
report and update incorporating goals agreed upon with OCR to the
Director of OCR at Headquarters for clearance prior to submitting
it to the appropriate field office of EEOC. At Headquarters the
reports and updates will be aggregated into an Agencywide AAP
to be submitted for approval to the Administrator. All reports
and updates are due at EEOC December 31, 1984.
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v
As required by EEOC, EPA as an Agency and each P/R Unit
will report data on all permanent employees, both full-time
(PFT) and part-time (PPT). The Civil Rights computer reports
in the SAS system have been revised, and now include a "PER"
report which combines full-time and part-time employees. This
should facilitate completion of the EEOC forms.
The EEOC forms listed below will be used by EPA P/R Units to
complete MD 707A. No other forms may be used to supply the
information requested without prior approval from OCR. Any
substitute forms, including ADP forms, must conform both.in
content and layout to the EEOC forms.
Accomplishment Reports
Form 504 - Accomplishment Report Cover Sheet (CRO2PER 4)
Forms 505 and 505A - Change in Work Force EEO Profile by
JPATCO and for Occupational Series of 100 or more (CRO4PER4)
Forms 506, pages 1-3 - Change in Work Force EEO Profile
by Pay Level (CRO2PER4)
Forms 507 and 507A - Distribution of.EEO Groups and
Underrepresentation Indices by PATCO and Pay Level (CRO4PER4)
Forms 508 and 508A - Hiring Goal Accomplishments
by PATCO and for Occupational Series of 100 or
more (CRO4PER4, EEO 50 & 51)
Forms 509 and 509A - Internal Movement Goal Accom-
plishments by PATCO and for Occupational Series of
100 or more (CR04PER4, EEO 50 & 51)
Form 510 - Barrier Elimination
i
NOTES:
1) Underrepresentation Indices for Forms 507 and
507A will be based on census data in the
revised Appendix B for each specific PATCO
category.
2) To the extent practicable, please use both
forms 508 and 509 distinguishing between
"HIRING" and "INTERNAL MOVEMENT". If this
is not possible, please provide an explana-
tion on the forms.
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3) "A" Forms are to be used only by P/R Units
having one hundred or more persons in a
single occupational series. When an "A* form
is used its totals are included on the summary
PATCO form.
Updates
Form 511 - Update Cover Sheet
Forms 512 and 512A - Hiring Goals by PATCO and for
Occupational Series of 100 or more
Form 513 and 513A - Internal Movement Goals by
PATCO and for Occupational Series of 100 or more
Form 514 - Projected Barrier Elimination
«
NOTES:
1) P/R Units should estimate which portion of tar-
geted vacancies will be filled through external
hire and which through internal movement and
distribute the goals accordingly between Forms
512 and 513.
2) Barriers in various series or PATCO categories
should be addressed on Form 514 whether or not
vacancies are projected in them.
In addition to the EEOC Forms, a narrative statement
should be attached to describe relevant activities in the
the Affirmative Action Program that are not reported else-
where or in your view require more explanation than is pos-
sible in the forms provided.
A statment of certification of the qualifications of
all EEO Officials must be attached. A format to be used for
this purpose is attached.
Please contact me (FTS 382-4564) with any questions
regarding these instructionst those included in MD 707A or
any other matter relevant to completion the required reports,
Thank you for your cooperation and assistance.
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Attachments:
1) Policy Memorandum on 1985 AAP (Aim)
2) Memorandum on Development of 1985 AAP (Scurry)
3) EEOC Forms 512 and 513 for use in submission of proposed
goals to OCR
4) Appendix B (Revised) - Interpretation and Instructions
- Pertinent Census Data for use
in Preparing AAP
5} Affirmative Action Tracking Report - Summary and EEO
Computer Reports 50 and 51
4
6) Charts showing 1984 accomplishments and 1985
objectives
7) MD 707A - Instructions for Preparing Affirmative Action
Accomplishment Reports & Updates for Minorities. &
Women
8) Set of EEOC forms for MD 707A
9) Certification of Qualifications of Principal EEO Officials
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
OFF ICE OF
CIVIL RIGHTS
NOV 2 I 19&3
MEMORANDUM . .
SUBJECT: Affirmative Action Goals for FY 1985
FROM: Nathaniel Scurry, Director
Office of Civil Rights (A-105)
TO: Charles R. Jeter, Regional Administrator
EPA - Region IV
We have reviewed the affirmative action goals proposed by your
Region and have approved them- as appropriate for your location and
consistent with Agency policy. I have attached a copy of Forms 512
and 513 confirming the goals. Your Region should now complete
preparation of the Affirmative Action Plan documents (Accomplishment
Report for FY 1984 and Update for FY 1985) and submit them to this
office as soon as possible so that we can review them prior to
submission to the Equal Employment Opportunity Commission (EEOC).
As I indicated earlier, EEOC expects our Plans on time this
year. You will note from the attached memos, that EEOC has already
notified us that they will be continuing their on-site reviews of
our programs across the Agency. We want to have our Plans in place
throughout EPA in order to document our accomplishments in 1984 and
to highlight actions to meet our 1985 objectives. i
While the goals which we submit to EEOC do not focus on specific
grade levels, either in hiring or in internal movement, we expect
that your Region will plan appropriate actions to improve the
representation of women and minorities at the upper grade levels and
in management positions. By separate memo we will be asking you to
report to us concerning your plans and strategy to accomplish this
objective, through workforce development and use of the Upward
Mobility Program. We will be reviewing these with the Office of
Human Resources Management and the Personnel Management Division who
have primary responsibility in these areas to ensure that the policy
established in the Deputy Administrator's memo of October 5, 1984
is implemented throughout EPA.
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Please note that an explanation in footnote or narrative should
be included in your Plan for any goals set where the analysis on Form
507 suggests that full representation already exists, e.g. targeting
engineering vacancies for Black males where they are underrepresented
although they may be fully represented in the professional category
as a whole. . . .
While your actual hiring projections for technical and clerical
staff nay include target group members such as White and/or Black
females, you should not include Affirmative Action goals for these
groups in the Plan to be submitted to EEOC unless these particular
groups are in fact underrepresented in your workforce. You nay wish
to reconsider the need to target minority males for certain clerical
and technical positions since in most cases their underrepresentation
is not based on discrimination but preference. In the latter case*
you are not required to set goals in these categories.
I look forward to working with you in carrying out our affirmative
action commitment to improving the representation of women and minori-
ties at all "levels of EPA's workforce.
Attachments:
Forms 512 and 513
Memo to EEOC, November 16, 1984
Memo to EPA, November 2, 1984
cc: Regional Director of Civil Rights
Regional EEO Officer
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ENVIRONMENTAL PROTECTION AGENCY
PLANNING AND REPORTING UNITS
EPA OFFICE . EEOC OFFICE
Headquarters . Headquarters
401 M Street, S.W.
Washington, O.C. 20460
PTSs 8-382-4575
Region I New England
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
FTSs 8-223-7210
Region XX Eastern
26 Federal Plaza
Room 900
New York, NY 1027B
FTS: 8-264-2525
Region XXI Mid-Atlantic
Curtis Building
6th and Walnut Street
Philadelphia, PA 19106
FTS: 8-597-9800
Region XV Southeast
345 Courtland Street, N.E.
Atlanta, GA 30365
FTSs 8-257-4727
Region V Great Lakes
230 South Dearborn Street
Chicago, XL 60604
FTSI 8-353-2000
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Region VI
1201 Elm Street
Dallas, TX 75270
PTSs 8*729-2600
Southwest
Region VII
324 East llth Street
Kansas City, NO 64106
FTS: 8-758-5493
Hid Continent
Region VIII
1860 Lincoln Street
Denver/ CO 80295
FTS: 8-327-3895
Rocky Mountain
Region IX
,215 Fremont Street
San Francisco, CA 94105
FTS: 8-454-8153
Western
Region X
1200 Sixth Avenue
Seattle, HA 98101
FTS: 8-399-5810
Northwest
Cincinnati Area EEO Office
26 West St. Clair Street
Cincinnai, OH 45268
FTS: 8-684-7940
(Serves Laboratories at
Cincinnati, OH and Ann Arbor, MI)
Great Lakes
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Las Vegas Area EEO Office
P.O. Box 15027
Las Vegas, NV 89114
FTSi 8-545-2512
(Serves Laboratories at
Ada, OK; Athens, GAi Corvallis, OR;
Duluth, MN; Gulf Breeze, PL;
Las Vegas, NV; Narragansett, RI;
and the National Environmental
Investigations Center in Denver, CO)
Western
Research Triangle Park (RTP) Area
EEO Office
Research Triangle Park, NC 27711
FTS: 8*629-4249
(Serves Laboratories at Montgomery, AL
and RTP, NC)
Southeast
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ffi
EPA
Regional
'^^^
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