AGENCYWIDE
\
Accomplishment Report
1986
Update 1987
Civil Rights
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ENVIRONMENTAL PROTECTION AGENCY
AGENCYWIDE AFFIRMATIVE ACTION PLAN
TABLE OF CONTENTS
ACCOMPLISHMENT REPORT: FY 1986 Page
Form 504: Accomplishment Report of Affirmative Action for Minorities 1
and Women
Form 505: Summary Sheet, FY 85 - FY 86 Change in Work Force EEO 2
Profile by PATCO
Form 507: Summary Sheet, Distribution of EEO Groups and Under- 3
representation Indices by PATCO and Pay Level
Form 508: Summary Sheet, FY 86 Hiring Goal Accomplishments by PATCO 5
Form 510: Barrier Elimination .6
ANNUAL UPDATE; FY 1987 Page
Form 511: FY 87 Annual Update of Affirmative Action Program for 12
Minorities and Women
Form 512: Summary Sheet, FY 87 Hiring Goals by PATCO 13
Form 514: Projected Barrier Elimination 14
NARRATIVE STATEMENT 20
STATEMENT OF ACCOUNTABILITY 23
CERTIFICATION OF QUALIFICATIONS OF PRINCIPAL EEO OFFICIALS 24
ATTACHMENTS:
EPA's 1987 Affirmative Action Policy and Program Objectives 25
EPA Policy Statement on Prohibition of Sexual Harassment 27
Memo: FY 87 Affirmative Action Policy and Program Objectives 28
Memo: Prohibition, Prevention and Resolution of Sexual Harassment
at EPA 30
Memo: Policy Statements on Affirmative Action and the Prohibition
of Sexual Harassment (to all employees) 31
Memo: Development of 1987 Affirmative Action Plan 32
Memo: Guidance and Instructions for Development of 1987
Affirmative Action Plan 35
List of EPA Planning and Reporting Units 41
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FY«6 ACCOMPLISHMENT REPORT OF AFFIRMATIVE
ACTION FOR MINORITIES AND WOMEN
REPORT BYt
P/R UNIT
.COMMAND
.COMPONENT
-AGENCY
Name of Reporting
Agency, Command
Component or P/R Unit
Responsible Agency
Official:
Environmental Protection Agency
Lee M. Thomas, Administrator
(Nome and title)
401 M Street, S.W. (A-lOO}
(Address)
Washington . T).C.
382-4700
(Telephone number • commercial or FT5)
{Signature of the responsible official)
Numter of Planning/Reporting Units (reports are.
(Date)
are not
attached):
Number of Commands/Components (aggregate reports attached, if appropriate):
SELECTED AGENCY FY 8 STATISTICS:
Number of employees at beginning of report year'
Number of employees at end of report year
Number of employees separated from the agency
due to RIF's: Q
GS/GM SES AD.EX.ST Sysflms CC TOTAL
11 81 7 97Q
30
12.206 217
26
70
248 12,404
242 12,761
Wh M:t
Wh F:.
BIM:
Bl F:
HIM:
HI F:
A AtPI M:
AA/PI F:
AH AN M:
AI/AN F:
Number of vacancies that had been originally projected:
P 602 A 311 T 28 C 229 O 5
Total 1225
Key:
AD - Administratively Determined
ED - Experts 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 - Commissioned Corps, Public Health Service
NAME OF PERSON WHO PREPARED REPORT
Cecelia F. Scott
TELEPHONE NUMBER
382-4563
EEOC
504
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SUMMARY SHEET
FY 8 5- FY 86CHANGE IN WORK FORCE EEO PROFILE BY PATCO
REPORT BYl
P/RUMIT
COMMAND
COMPONENT "
AGENCY
CATEGORIES
PROFESSIONAL
ADMINISTRATIVE
TECHNICAL
CLERICAL
OTHER
TOTAL
YEARS/
* CHANCE
•
1985 %
*
1966 «
% CHANGE
«
iaa5 n,
t
1986 X
* CHANGE
*
1985 %
*
1M6 %
f
% CHANGE
f
ttt^ n
1986 %
% CHANGE
IT
198 %
0
198 %
% CHANGE
•
196 5 X
•
198 6 %
% CHANGE
TOTAL
ALL
5712
5890
3275
3467
916
864
2141
2202
L2044
L2423
FEMALE
1166
20.4
1301
22.1
1.7
1502
45.9
1654
47.7
1.8
598
65.3
569
65.9
.6
2038
95.2
2079
94.4
(.8)
5304
44.1
5603
45.1
1.0
WHITE
MALE
4056
71.0
4099'
69.6
(1.4)
1592
48.fi
1622
46.8
(1.8)
256
28.0
227?1
(.6)
50
2.3
51
2.3
0
5954
49.4
6009
48.4
(1.0)
FEMALE
982
17.2
1073
18.2
1.0
1182
Tfi.l
1284
37.0
.9
375
40.9
342
39.6
(1.3)
995
46.5
962
43.7
(2.8)
3534
29.4
3661
29.5
.1
•LACK
MALE
194
3.4
201
3.4 -
0
125
?:R
132
3.8
0
48
5.2
43
5.0
(.2)
42
2.n
56
2.5
.5
409
3,4
432
3.5
.1
FEMALE
98
1.7
120
2.1
.4
266
8.1
318
9.2
1.1
205
22.4
206
23.9
1.5
958
44.7
1018
46.2
1.5
1527
12.7
1662
13.4
.7
HISPANIC
MALE
100
1.8
96
1.6
(.2)
31
1.0
33
1.0
0
8
.9
.8
(.1)
.1
8
.4
.3
142
1.2 .
144
1.1
(.1)
FEMALE
31
.5
43
.7
.2
18
.6
19
.6
0
. 8
.9
tf
.5
64
3.0
65
3.0
0
121
1.0
139
1.1
.1
ASIAN AMERICAN/
PACIFIC ISLANDER
MALE
190
3.3
188
3.2
(.1)
20
.6
22
.6
0
.5
8
.9
.4
.!
6
0
221
1.8
224
1 R
0
FEMALE
54
i.n
' 65
. l.l
.1
32
, !'0
29
.8
(.2)
8
.9
8
.9
0
14
24
1.1
.4
108
.9
126
1.0
.1
AMERICAN INDIAN/
ALASKAN NATIVE
MALE
6
.11
5 -
.08
(.03)
.15
4
.12
(.03)
.ii
0
0
(.11)
2
.09
2
.09
0
14
.12
11
.09
(.03)
FEMALE
1
.n?
0
n
(.02)
4
.12
fl2
0
2
.22
!l2
(.10)
I*
10
.45
.12
14
.12
*12
0
N>EEOC FORM 505
-------
SUMMARY SHEET
DISTRIBUTION OF EEO GROUPS AND UNDERREPRESENTATION
INDICES BY PATCO AND PAY LEVEL
REPORT BYt
X
P/R UNIT
AGENCY
OCCUPATIONAL
CATEGORY
AND SES
SES
(INCLUDE GS/GM
1« - IB)
PROFESSIONAL
ADMINISTRATIVE
TECHNICAL
PAY
•LEVEL
OS 1 -4
OS 6 - 8
CS 9 • 12
GS/GM 1J - 18
• 1
TOTAL
GS*1 -4
OS 5 -8
CS 9 - 12
GS/GM 1* . IS
TOTAL
OS 1 .4
OS 5- 8
GS 9 • 12
GS/GM «» - 18
TOTAL
TOTAL
230
289
2694
2774
5757
227
1690
1453
3370
10
610
243
1
864
WHITE
MALE
NUMBER
198
117 .
1635
2225
3977
46
592
908
1546
3
93
140
1
237
FEMALE
NO.
23
87
640
340
106;
112
753
402
12 61
4
283
55
0
342
U.I.
**
37
112
88
45
69
*
144
*
130
§1
11*0
*
117
*
136
*6
0
*
116
BLACK
MALE
NO.
7
18
L07
72
L97
12
72
45
L29.
1
25
17
0
43
U.I.
**
130
267
170
111
146
*
L07
*
86
85
*
77
*
>02
*
83
4*1
0
*
LOO
FEMALE
NO.
0
29
70
21
.20
52
!05
61
J18
1
180
25
0
206
U.I.
0
359
93
27
74
4*3
*
250
§6
*
195
206
*
609
*
212
0
*
492
HISPANIC
MALE
NO.
1
12
63
21
96
2
13
17
32
0
5
2
0
7
U.I.
**
19
192
108
35
77
31
27
42
34
0
30
30
0
30
FEMALE
NO.
0
8
27
8
43
0
16
3
19
0
12
0
0
12
U.I.
0
242
87
25
65
0
73
16
43
0
81
0
0
57
ASIAN AMERICAN/
PACIFIC ISLANDER
MALE
NO.
1
7
108
72
187
1
12
9
22
1
5
2
0
8
U.I.
*
50
281
466
*
302
*
377
*
51
*
82
*2
*
75
1162
*
95
*
95
0
108
FEMALE
NO.
' i
o.
11
41
13
65
2
22
5
29
0
6
2
0
8
U.I.
0
508
*
202
*
62
*
150
1*7
*
173
66
*
114
0
*
130
*
109
0
*
124
AMERICAN INDIANA
ALASKAN NATIVE
MALE
NO.
0
0
3
2
5
0
2
2
4
0
0
0
0
0
UJ.
0
0
52
33
42
0
4*0
*6
4*0
0
0
0
0
0
FEMALE
NO.
0
0
0
0
0
0
3
1
4
0
1
0
0
1
UJ.
0
\" '
0
0
0
0
0
8*1
41
70
0
*
72
0
0
*
54
EEOC
FORM
507
* Based on undifferentfated CLF.
** Based on comparison with Professional Labor Force.
-------
DISTRIBUTION OF EEO GROUPS AND UNDERPRESENTATION
INDICES BY PATCO AND PAY LEVEL
OCCUPATIONAL.
CATEGORY
SERIES
CLERICAL
OTHER
PAY
LEVEL.
091-4
os s -a
OS • . 12
GS/GM If- 15
TOTAL.
OS 1 - 4
css-e
OS • - 12
GS/OM 1* • tS
TOTAL
TOTAL
574
1556
72
2202
WHITE
MALE
NUMBER
21
30
0
51
FEMALE
NO.
180
74"?
37
962
U.I,
*
92
*
140
*
150
*
128
•LACK
MALE
NO.
31
2,5
0
56
1
U.I.
*
109
"jfi
0
*
91
FEMALE
NO.
290
694
34
101*
U.I.
*
104:
*
921
*
97f
*
95'.
HISPANIC
MALE
NO.
4
L
0
8-
U.I.
37
13
0
53
FEMALE
NO.
28
17
0
,65
U.I.
*
192
*
91
0
*
116
ASIAN AMERICAN/
PACIFIC ISLANDER
MALE
NO.
3
1
0
6
U.I.
76
77
0
39
FEMALE
NO.
13
jn
1
24
U.I.
*
301
*
8S
*
18-5
*
145
AMERICAN INDIAN/
ALASKAN NATIVE
MALE
NO.
1
1
0
2
UJ.
*
56
sn
0
75
FEMALE
NO.
3
7
Q
10
UJ.
*
236
*
?pA
Q
*
204
•
* Based on undifferentlated CLF.
BEOC FORM SOT (•/»»)
PAQEI
-------
SUMMARY SHEET
FY 86 HIRING GOAL ACCOMPLISHMENTS BY PATCO
REPORT BY I
P/RUNIT
_____ COMMAND
_____ COMPONENT
X AGENCY
OCCUPATIONAL
CATEGORY
P
T
• C
o
PLANNED/
ACTUAL
602
PLANNED 0
ACTlTAi. 0
PLANNED 0
311
ACTUAL •
606
PLANNED 0
78
ACTUAL 0
150
PLANNED 0
229
ACTUAL 0
488
PLANNED 0
5
ACTUAL 0
0
PLANNED 0
1225
«?»#•
PERCENT
• TOTAL
ALL
336
352
194
370
47
117
39
4W
3
619
1314
212 %
FEMALE
278
298
124
335
32
111
26
449
2
462
1193
258 %
WHITE
MALE
&*"*$??
Afl^Vr
443
??&$*;
'HX'^''.
236
SfeiMi
33
:Cl§S§'l
13
$$$?-l^$
u$t$S$fj£--
StSlSi
lisps
'?;iRfe"£-£
725
1p55'I
TT^
FEMALE
181
234
48
261
13
55
15
170
1
258
720
279%
BLACK
MALE
18
25
39
23
9
1
7
19
1
94
68
72 %
FEMALE
fiA
36
53
68
12
48
1
243
1
131
395
301 %
HISPANIC
MALE
10
11
20
6
It.
2
5
. 6
0.
48
25
52 %
FEMALE
9H
14
20
3
7
6
8
19
0
fin
42
70 ^
ASIAN AMERICAN/
PACIFIC ISLANDER
MALE
1
17
8
6
1 •
3
0
1
0
in
27.
270 «
FEMALE
A
14
2
3
n
2
1
13
0
q
32
355%
AMERICAN INDIAN/
ALASKAN NATIVE
MALE
Q
1
3
0
0
1
0
0
5
1
20 i
FEMALE
9
0
1
0
0
0
1
4
0
A
4
100 ,
EEOC AFu°oRa 508
-------
BARRIER ELIMINATION
REPORT BYs
- P/R UNIT
„.«______ COMMAND
COMPONENT
X AGENCY
1. Number of Barriers Identified for Analysis and Elimination in FY 8g:.
2. Number of these Barriers Eliminated In FY 86 2
3. Number of these Barriers Partially Eliminated In FY 83
For each barrier addressed during the reporting year, indicate the occupations from which tt tended to exclude people*
whom it tended to exclude, and how the barrier was eliminated or partially eliminated (that Is, what alternative procedures
were Instituted to replace the barrier). Where the barrier was not eliminated, please explain what prevented Its elimination:
Barrier No. 1: See attached
Barrier No. 2:
EEOC
-------
A. LACK OF CLEARLY DEFINED RESPONSIBILITIES, OBJECTIVES AND
ACCOUNTABILITY OF MANAGERS AND SUPERVISORS FOR AFFIRMATIVE
ACTION.
This barrier has been eliminated among senior level and to a
substantial degree among mid-level and first-line supervisors,
Policies and procedures are in place to institutionalize
reiteration and clarification of responsibilities, objectives
and accountability for affirmative action. OCR will continue
to monitor this area and recommend appropriate corrective
action as necessary.
ACTION TAKEN;
1. The Administrator has issued annual statements of
Affirmative Action Policy and objectives with a clear
message about the responsibility and accountability of
EPA managers for achieving success in the Affirmative
Action Program. At the beginning of FY 87 this policy
and one on the prohibition of sexual harassment were
sent to all EPA employees. This practice will be
continued.
2. Most Agency components have instituted a system of
accountability for equal employment opportunity and
affirmative action achievements at the division level.
When this has occurred the greatest progress has been
made. The Office of Civil Rights (OCR) will encourage
remaining components to develop and institutionalize
such systems in FY 87.
3. Performance standards for most managers and supervisors
have been revised to incorporate a susbstantive standard
on human resource management and affirmative action
responsibilities.
4. The Director of OCR issued quarterly reports to senior
managers indicating progress in affirmative action
hiring and net gains and progress in upper grade levels
and in supervisory and managerial positions as well as
in the Upward Mobility Program. OCR will continue this
monitoring effort, providing information for self-
evaluation to each Agency component and focussing on an
extensive mid-year review and evaluation of progress.
5. EEO training for supervisors and managers has been
included as a component of a more comprehensive training
program for supervisors and managers during FY 86 and
will be continued in FY 87.
-------
Participation by senior and mid-level managers in a
Conference on the Environment, Minorities and Women
cosponsored by EPA and Atlanta University and in an
EPA College Career Day has increased their knowledge
and appreciation of affirmative action responsibilities
in recruitment.
OCR designated a representative to serve on the EPA
FAME (Framework for Achieving Managerial Excellence)
Task Force within the Office of Human Resources
Management. The task force is developing policy to
identify and train Agency employees to excel in all
aspects of managerial and supervisory work, including
EEO and Affirmative Action. OCR will work with the
.FAME Program to ensure inclusion of mandatory EEO
awareness training for all supervisors.
OCR has issued a draft version of the Affirmative
Action and Special Emphasis Program portions of the
EEO Manual for review and comment. The Manual includes
a description of the specific responsibilities of
managers and supervisors, as well as those of EEO
staff and Personnel.
B. 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
The Agency has focussed considerable attention on developing
the full potential of its employees. Several initiatives
are underway and more are planned.
ACTION TAKEN;
1. The Human Resources Council at the Agency level and
its local counterparts across regions, labs and
program offices are identifying needs and developing
appropriate training and developmental opportunities
for EPA employees. As a matter of policy these
groups are to be representative of the total workforce.
OCR has been assertive in seeking to ensure adequate
participation of minority group members at the national
level and on local groups.
2. Two task groups formed under the aegis of the Office of
Human Resources Management (OHRM), the Scientific and
Technical Careers Advisory Committee and the Support
Careers Advisory Committee have made substantial headway
8
-------
in initiating and implementing projects to address the
career and professional development needs of both the
scientific and the secretarial staff of the Agency.
a) The Administrator recently issued a policy statement
supporting membership and particpation in profes-
sional societies and conferences to further the
development of our scientific and technical staff,
a policy prepared and recommended by the Scientific
and Technical Careers Advisory Committee.
b) Several active subcommittees are addressing the
needs of secretarial and other support staff for
career development training, both within the
secretarial field and out of it into other career
fields. Secretaries chair all subgroups and have
participated as trainers in courses for both
secretaries and managers in effective office
management.
3. The EPA Institute concept is being fully implemented
whereby EPA employees become teachers/trainers in
their fields of expertise in a large cadre of courses
open to EPA employees Agencywide. This includes
staff at all levels and types of careers within EPA,
support positions as well as highly technical and
scientific ones. Women have formed a substantial
portion of the instructors. OCR has been asked to help
identify more minority instructors across the Agency.
4. The Agency has placed strong emphasis on use of
rotational assignments and details to provide career
enhancement through broadened experience. Extensive
use is being made of this approach both at Headquarters
and in the field.
5. The Upward Mobility Program has gained momentum in
FY 86. Eighty-four positions were filled, about 68%
of the Agency's goal for establishing and maintaining
Upward Mobility positions.
6. The SES Candidate Program has been extensively
publicized and the pool of potential applicants
expanded to the Grade 14 level. Nine women, including
one Black, out of twenty-four total, were selected for
this program at the close of FY 86. A new "class" will
be selected during the second quarter. Relatively few
minority group members applied. Analysis of potential
applicant pool indicates a need to increase develop-
mental opportunities for women and minorities at the
mid-level in preparation for management positions.
-------
C. LACK OF SUFFICIENT TRAINED STAFF IN EEO AND PERSONNEL TO
FACILITATE EFFECTIVE RECRUITMENT
This barrier was partially eliminated during FY 86.
ACTION TAKEN;
1. EEO and Personnel staff have continued to increase
regular contact and improve coordination in an effort
to develop more effective recruitment across the Agency.
This will be continued in FY 87.
2. The Personnel Management Division (PMD) has instituted a
training program for Agency recruiters including
Personnel, EEO and Program staff who will be involved
in interviewing potential candidates. This training
will continue during FY 87, expanding the cadre of Agency
staff trained for assuming recruitment responsibilities.
3. OCR conducted a training program for Regional and
Laboratory EEO Officers in June 1986 including affirma-
tive action and a presentation by the Agency's Director
of Personnel on the Agency's strategy for improving
recruitment.
4. OCR staff included training related to recruitment and
other aspects of affirmative action in annual agencywide
training for Special Emphasis Program Managers in the
Black Employment Program, Federal Women's Program and
Hispanic Employment Program.
D. LIMITED USE OF CREATIVE STAFFING TECHNIQUES
On a broad agencywide basis this barrier has been eliminated.
ACTION TAKEN;
Extensive use of details, rotational assignments, inter-
disciplinary positions and some job restructuring have
taken place with the initiative and urging of OHRM,
Personnel and EEO staffs. Regions, in particular, are
making increased use of the Cooperative Education Program,
While some managers remain reluctant to make use of
these options to increase flexibility in staffing, the
issue is no longer a major Agency barrier. OCR and PMD
will continue broad efforts to educate managers and
address particular situations on a case-by-case basis.
10
-------
E. INSUFFICIENT TIME ALLOTTED BY MANAGERS AND SUPERVISORS FOR
COLLATERAL DUTY EEC PERSONNEL TO PERFORM EEO DUTIES
Some progress has been made in this area. However, few
collateral duty managers are permitted to perform EEO
duties beyond 15-20% because of work requirements in their
primary jobs, and employees who serve on EEO/SEP committees
are often discouraged or restricted in their participation
by supervisors.
ACTION TAKEN;
1. The Agency has issued Special Emphasis Program Guidance,
which establishes 25% as the minimum time for collateral
duty assignments in an SEP. The Guidance states
clearly the responsibilities of the SEPMs and provides
guidance in developing and conducting effective
programs in each location.
2. In FY 86, the Agency issued a Special Emphasis Program
Handbook to provide assistance to collateral duty SEPMs
in the ongoing operation of their programs.
3. Strong communications linkages continue among the SEPs,
and the SEPMs have received comprehensive guidance in
the conduct of programs through conference calls and
mailings, as well as the SEP Guidance and Handbook.
4. OCR officials have encouraged establishment of new SEPs,
such as the Black Employment Program, where no program
has existed in the past and the speedy replacement of
collateral duty SEPMs as necessary.
5. National SEPMs conducted annual training for each SEP
(BEP, FWP and HEP) with emphasis on identifying and
addressing issues, effectively developing work plans and
budget, affirmative action responsibilities, and
developing effective working relationships with both
constituents and Agency management.
F. INABILITY TO REACH QUALIFIED NON-STATUS APPLICANTS
Blocked or closed Office of Personnel Management (0PM)
registers keep prospective applicants from getting onto the
registers and prevent 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. This barrier continues
to seriously limit affirmative action hiring efforts. The
Personnel Management Division has requested from 0PM
delegated examining authority and direct hire authority
for several key scientific "and engineering occupations.
Response to this from OPM is pending.
11
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FY 8 7 ANNUAL UPDATE OF AFFIRMATIVE ACTION
PROGRAM FOR MINORITIES AND WOMEN
REPORT BY«
P/R UNIT
COMMAND
COMPONENT
AGENCY
Name of Reporting
Agency, Command*
Component or P/R Unit: Environmental Protection Agency
Responsible
Agency Official:
Lee M. Thomas, Administrator
(Name and Title)
401 M Street, S.W. (A-100)
Washington, D.C.
382-4700
(Telephone Number • Commerical or FT5)
(Signature of the Responsible Official)
Number of Planning/Reporting Units (updates are ^ are not attached):
Number of Commznds/Components (aggregate updates attached. If appropriate):
(Date)
Number of vacancies projected for year of update by PATCO category:
p 666 A 308 T 66 c 263 Q 0
Total 1303
NAME Of PREPARE* OP REPORT
Cecelia F. Scott
TELEPHONE NUMBER
382-4563
EEOC 'ORM 511
AUOM
12
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SUMMARY SHEET
FY 87 HIRING GOALS BY PATCO
PERMANENT
REPORT BYl
P/R UNIT
'COMMAND
COMPONENT
F.PA
t-
OCCUPATIONAL
CATEGORIES
PROFESSIONAL
t *
ADMINISTRATIVE
TECHNICAL
CLERICAL
OTHER
TOTAL
PLANNED
666 '
PLANNED
f
308
PLANNED
66
PLANNED
f
263
PLANNED
1
PLANNED
1303
* TOTAL
ALL
380
175
24
72
'
651
FEMALE
297
95
15
52
459
WHITE
MALE
lisi
!ir>T>T; *'S H.
!;:i;-*!'S^''r''
-------
PROJECTED BARRIER ELIMINATION
UPDATE BY:
. P/RUNIT
.COMMAND
'COMPONENT
AGENCY
1. Number of barriers to be addressed In plan year: 5
2. Describe each barrier, the occupations it tends to exclude people from, whom it tends to exclude, and how It will
be addressed: See attached pages.
a.
During FY 87, we plan to seek resolution of the four barriers which were
partially eliminated in FY 86 and develop'strategy for- addressing one
additional barrier .
EEOC /O"N 514 14
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A. 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
ACTION PROPOSED;
1. The Office of Civil Rights (OCR) will continue to work
closely with the task groups established by the Office
of Human Resources Management (OHRM), the Scientific
and Technical Careers Advisory Committee, the Support
Careers Advisory Committee, and the Framework for
Achieving Managerial Excellence Committee, to assure
that policies and programs implemented as a result of
their efforts provide for full participation of women
and minorities.
2. A task group to develop a program modeled after the
Women's Executive Leadership Training Program piloted
by the Office of Personnel Management was formed by
OHRM. Representatives of the Federal Women's Program
have served on this task group which has prepared a
draft proposal to be refined and developed into a
pilot program during FY 87. This program is speci-
fically aimed to serve employees in grades 9-12
where a critical gap in training and developmental
opportunities has existed.
3. The Personnel Management Division, with assistance
from OHRM and OCR, will conduct an evaluation of the
effectiveness of the Upward Mobility Program with a
view to determining and instituting needed revisions
and/or developing alternative or supplemental programs.
This will involve consulting both managers and program
participants, reviewing the basic concept, policies
and practical implementation of the program.
4. OCR will continue to analyze policies and practices
among the range of Agency human resource development
programs to assure appropriate inclusion of women and
minorities in both planning and implementation. Such
inclusion was incorporated as policy into the statement
of FY 87 Affirmative Action Policy and Program Objectives
signed by the Administrator in November 1986.
5. OCR will continue to monitor progress in increasing the
representation of women and minorities in grades 13 -
15 and in supervisory and managerial positions.
15
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B. LACK OF SUFFICIENT TRAINED STAFF IN EEO AND PERSONNEL TO
FACILITATE EFFECTIVE RECRUITMENT
ACTION PROPOSED:
1. The Personnel Management Division (PMD) will develop
guidance in recruitment for distribution to all EEOf
Personnel and Program staff with responsibility for
recruitment. PMD has developed a training program for
recruiters focussing on effective interviewing. This
will be offered throughout the Agency to ensure that
all recruiters are properly prepared for their role.
It will significantly expand the cadre of qualified
recruiters.
2. PMD is placing increased emphasis on effective re-
cruitment in light of extensive hiring planned as a
result of reauthorization of "Superfund." Additional
staff will be added to the National Recruitment and
Employment Center in order to put in place both
coordinated outreach at colleges, conferences, etc.
and effective circulation and tracking of applications.
3. OCR will continue to conduct conference calls with SEPMs
and EEO Officers to provide guidance in recruitment and
to provide a forum to respond to specific questions
about the current status of each of the programs. As
appropriate, the conference calls will involve both EEO
and Personnel staff.
4. National SEPMs will continue to provide training and
information on recruitment in their annual BEP, FWP and
HEP training conferences.
5. OCR, with assistance from Personnel, will conduct
training activities for EEO Officers and other EPA
personnel with responsibilities in EEO and Affirmative
Action.
16
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C. INSUFFICIENT TIME AND RESOURCES ALLOCATED BY MANAGERS AND
SUPERVISORS FOR COLLATERAL DUTY EEO PERSONNEL TO PERFORM
EEC DUTIES
ACTION PROPOSED:
1. The Agency's Special Emphasis Program Guidance clarified
the purpose and responsibilities of the SEPMS, as well
as the means of determining the need for the programs
and resources to support them. It has been incorporated
in an EEO Manual currently being circulated in draft
for review. This guidance clarifies the scope of the
programs and provides an appropriate basis for allocating
resources, including adequate time for performing EEO
duties.
2. OCRf in its formal Program Evaluations of Agency
components, will seek to identify those areas where
SEPs need additional support and resources to function
effectively and make recommendations for specific
action to correct these deficiencies.
3. During FY 86 the Agency issued a Special Emphasis
Program Handbook to provide SEPMs with specific opera-
tional guidance to develop and carry out effective
programs. OCR will complete this handbook with supple-
mental information on each of the individual SEPs. OCR
will also update the handbook as necessary to aid SEP
managers and committees in carrying out these programs.
This should assist in improving productivity to make
maximum use of the time and resources allocated.
4. Consistent with the SEP Guidance, a memorandum of
understanding will be developed between each SEP Manager
and supervisor spelling out, in detail, the agreement
in performing collateral EEO duties.
5. OCR officials will continue to encourage establishment
of SEP managers and programs where no programs currently
exist, and encourage Agency officials to establish full
time SEP Managers at locations where the population and/
or underrepresentation warrant it.
6. OCR will continue to conduct yearly training programs
for all SEP Managers to increase their effectiveness.
17
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D. INABILITY TO REACH QUALIFIED NON-STATUS APPLICANTS
Blocked or closed Office of Personnel Management (OPM)
registers prevent prospective applicants from getting onto
them; this 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.
ACTION PROPOSED;
1. The Agency has requested from OPM direct hire authority
for five key scientific job series to augment that for
environmental engineers and its delegated examining
authority for environmental protection specialists.
EPA's Personnel Management Division is currently nego-
tiating these with OPM. Resolution is anticipated
early in the second quarter of FY 87. At a minimum,
OPM will be asked to open its registers for certain key
occupations. These actions will permit wider, more
diverse applicant pools including minorities and women
not now in the Federal workforce.
2. EPA officials in each Region will also work closely with
OPM officials in their Region to resolve problems with
blocked or closed registers.
E. PERCEPTION BY SOME MANAGERS THAT MINORITIES AND WOMEN ARE
NOT QUALIFIED FOR SUPERVISORY AND MANAGERIAL ROLES.
This attitudinal barrier results in screening out of many
minorities and women from consideration for supervisory and
managerial positions. It also tends to exclude them from
participation in those pre-supervisory training and develop-
mental programs which will help them to qualify at a later
time for such positions. Thus it serves to inhibit growth
of the pool of qualified minority and female candidates.
It also reinforces the perception that there are few or no
qualified candidates among minorities and women.
EPA plans to address this barrier through two approaches:
1) seeking to heighten EEO sensitivity and awareness of
this issue among managers and 2) increasing opportunities
and abilities of minorities and women to demonstrate their
skill and potential for these positions.
18
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ACTION PROPOSED;
1. The Special Emphasis Programs, working with Personnel
and Human Resources Councils, will provide appropriate
workshops, seminars and other training in documenting
and presenting relevant managerial experience through
resumes and applications and through interviews. This
includes stressing experience gained in ways other than
traditional formal supervisory positions, managing pro-
jects outside, as well as inside, the work place.
2. OHRM, working with OCR and Personnel, will put increased
emphasis on mid-level targeted training such as that
being developed through the task group on leadership
opportunities for women. Such training addresses specific
needs of the constitutent group, enhances the development
of potential supervisory candidates, and increases their
visibility to senior management. A mentoring component
will be incorporated in such training.
3. OCR will encourage programs to solicit the active
participation of minorities and women in opportunities
to demonstrate and hone their skills through details,
rotational assignments, project management roles, tem-
porary promotions to acting supervisory roles, teaching
in the EPA Institute, etc.
4. EEO/SEP staff will work with Personnel and Human Resources
staff and Public Affairs to publish and highlight the
"success stories" of minorities and women within the
Agency, thereby increasing their visibility to managers
and as role models to others.
5. EEO/SEPs will plan special observances for Black History
Month, Women's History Month and Hispanic Heritage Week
with emphasis on highlighting "competence" of constituent
group members to managers and peers.
6. EEO staff will work with Personnel and Human Resource
Councils to provide more formal EEO Awareness Training
for managers throughout the Agency and incorporate
segments of it into general supervisory training.
19
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NARRATIVE STATEMENT - EPA AGENCYWIDE
1986 ACCOMPLISHMENT REPORT
During FY 1986, EPA continued its comprehensive agencywide
strategy in establishing and pursuing its Affirmative Action
goals. We sought to improve representation of women and
minorities in our workforce agencywide by considering 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. We
placed emphasis upon the Professional and Administrative (P&A)
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.
Each Agency component was asked to target a minimum of 52% of
its P&A vacancies for affirmative action hiring. Goals were
developed on the basis of available opportunities for hiring,
taking into account, but not exclusively reflecting the relative
levels of representation in particular Planning and Reporting
(P/R) Units. For example a Regional Office with large numbers of
projected vacancies targeted more positions 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.
However, each component set goals reflecting the relative under-
representation of specific groups. These were aggregated and ana-
lyzed at -the Agency level to assure progress in the Agency as a
whole.
EPA achieved considerable success in meeting its 1986
goals; women and minorities comprised nearly 53% of all per-
manent hires in the P&A categories. Furthermore 80% of the
net gain in the P&A categories was comprised of women and mino-
rities. The actual percentage of women and minorities in the
Agency's P&A work force improved by 1.7 points this year. To
reduce the remaining gap, our 1987 plan continues aggressive
affirmative action recruitment while the Agency remains in a
hiring mode. The reauthorization of Superfund means that in
FY 87 and 88 the Agency anticipates substantial hiring. This
increases our potential for further improving the representation
of women and minorities in our workforce.
During the past year, EPA undertook targeted recruitment
designed to reach qualified women and minorities for scientific
and engineering positions. This included successful recruit-
ment for the third consecutive year, at the University of Puerto
Rico, as well as participation in the National Society of Black
Engineers Conference, the Mexican American Engineering Society
Conference, and several regional conferences.
In March 1986 EPA and Atlanta University cosponsored a
Conference on the Environment, Minorities and Women, involving
representatives of several Historically Black Colleges and
20
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Universities and women's colleges. Its purpose was to develop
ongoing relationships with these schools, encourage relevant
curriculum development and attract students into preparation
for careers in a range of environmental occupations. About
fifty schools participated. EPA also conducted a College Career
Day aimed at attracting students to environmental careers.
EPA's affirmative action program was highlighted in the Agency's
presentations.
During 1986 EPA also made good progress in linking affirma-
tive action to human resource development efforts throughout
the Agency/ establishing close working relationships with and
participation on task groups concerned with developing employees
to their full potential at EPA.
EPA improved representation of women and minorities in
upper levels by a small margin in FY 86, 1.5 percentage points
in grades 13 to 15 and 1.2 points in the Senior Executive
Service. This is a gain of over 6%.
We began to focus on increasing the representation of
women and minorities in supervisory and managerial positions.
Although few components set specific goals, most developed
strategies in connection with human resource development initia-
tives toward meeting this objective. In the Agency as a whole,
we improved representation of women and minorities in supervisory
and managerial positions by 2.1 percentage points, a gain of
nearly 10%.
In the Upward Mobility Program each Agency component was
asked to set aside positions, so that 1% of the Agency's total
permanent positions (125) would be committed to the Program.
During FY 86, 136 positions were targeted for the Upward Mobility
Program and 84 were filled, a 65% increase over FY 85.
To assure accountability we continued use of Affirmative
Action Tracking and Progress Reports as a mechanism for monitoring
progress in improving representation of women and minorities in
our workforce. These were issued quarterly to top managers.
1987 UPDATE
In 1987, EPA will continue to build upon its 1986 Agency-
wide approach with focus on hiring opportunities in the Profes-
sional and Administrative (P&A) job categories. As a matter of
Agency policy, each major Agency component was asked once again
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 the representation of women
and minorities in the Agency as a whole.
21
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Reauthorization of Superfund will result in substantial
increase in the number of hires and thus in the numbers targeted
for affirmative action. The allocation of positions will not
be completed until the early part of the second quarter. At that
time goals will be reviewed and adjusted as appropriate.
In addition to continuing last year's effort, EPA is
undertaking additional focus on two areas in 1987:
1. Emphasis will be placed through targeted recruitment
on those target groups most severely underrepresented
on each Agency component, rather than on hiring women
and minorities in general. We hope by this focus to
increase our success in reaching minority candidates,
Hispanics and Blacks in particular.
2. To institutionalize the linkage between affirmative
action and human resource development within the
Agency, EPA has incorporated in its affirmative action
policy the inclusion of women, minorities and handi-
capped individuals in Agency task forces and in plan-
ning, reviewing and participating in the whole range
of human resource development/training initiatives
and awards/recognition programs.
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 and organizational
units 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 positions where they are
severely underrepresented.
Explanatory Notes on Specific Forms
Information on Form 508 reflects the total gains into each
PATCO category, that is the sum of all new EPA hires, transfers,
conversions from temporary to permanent status, and promotions
into the respective job category. Promotions within a specific
job category are not included. Losses have not been taken into
account but may be figured by comparing the total gains with
the net changes on the Form 505.
Consistent with the variance approved by the Equal
Employment Opportunity Commission last year, we have continued
to develop underrepresentation indices (UI), so that setting
goals on Form 512 is linked directly to underrepresentation
documented on Form 507. In determining the 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.
22
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STATEMENT OF ACCOUNTABILITY
EPA assures accountability in Affirmative Action through
three principal means:
1. Policy statements issued by the Administrator
indicating commitment and expectations of the
Administrator regarding Affirmative Action and
Equal Employment Opportunity. (Attached)
2. A standard on resource management incorporating
performance in EEO responsibilities has been
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 issues data reports quarterly for analysis
of progress in meeting Affirmative Action goaLs.
These will be supplemented by an Agencywide mid-year
report issued by the Office of Civil Rights.
23
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CERTIFICATION OF QUALIFICATIONS OF PRINCIPAL EEO OFFICIALS
I 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
Regional Directors of Civil Rights
Equal Employment Opportunity Officers
Black Employment Program Managers
Federal Women's Program Managers
Hispanic 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 meet 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
available for reveiw by EEOC officials.
I further certify that provisions of FPM Letter 713-37,
Documenting EEO Collateral Duties in Official Position Descrip-
tions have been met.
h- fa I 1f4
Administrator Date
24
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FY 1987 AFFIRMATIVE ACTION POLICY AND PROGRAM OBJECTIVES
It is the policy of the Environmental Protection Agency
to provide equal opportunity for employment and advancement
to all employees and applicants regardless of race, color,
religion, sex, age, national origin, or physical or mental
handicap.
Further, EPA shall take affirmative action to remedy the
effects of past discrimination, developing its annual Affirmative
Action Program to identify and address inadequate representation
of women, minorities and handicapped individuals in our work-
force in accordance with directives from the Equal Employment
Opportunity Commission.
FY 1987 Goals and Objectives
In FY 1987, it Is the goal of EPA to increase the
representation of women and minorities in our workforce,
especially In professional and administrative positions.
Further, the Agency will seek to increase the representation
of handicapped employees in all job categories. A top priority
will be to develop and advance members of the target groups
within the Agency, especially in grades 13-15 and in management.
The Agency will continue to strive to meet its goal of filling
1% of all permanent positions through our Upward Mobility Program.
To meet these goals, you are responsible for seeking out,
selecting and actively supporting the development of qualified
target group members. Your task is to develop and carry out
an aggressive Affirmative Action Program which accomplishes
the following:
1) Assures that women and minorities comprise at least
52% of professional and administrative hires and
that members of those groups most severely under-
represented in your workforce are included among
your hires.
25
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-2-
2) Increases representation of women and minorities
in upper level positions (Grades 13 - 15) and in
managerial and supervisory roles.
3) Increases representation of severely handicapped
individuals in the workforce.
4) Maintains a level of participation in the Upward
Mobility Program at 1% of all permanent positions.
5) Identifies and involves women, minorities and
handicapped Individuals in Agency task forces and in
planning, reviewing and participating in human re-
source development/training initiatives and awards/
recognition programs.
•" ' 6) Institutes an effective accountability and reward
system for achieving equal employment opportunity.
It is your responsibility to Implement these policies and
meet the program objectives which have been established. This
is an Important area of your performance, and I have asked the
Deputy Administrator to periodically review and evaluate our
progress in meeting Civil Rights objectives throughout this
fiscal year.
Lee M. Thomas
Administrator
NOV 2 8 1986
26
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ENVIRONMENTAL PROTECTION AGENCY
POLICY STATEMENT ON PROHIBITION OF SEXUAL HARASSMENT
Employees of the Environmental Protection Agency have a grave
responsibility under the Federal code of conduct and ethics for
maintaining high standards of honesty, Integrity, impartiality
and conduct to assure proper performance of the Government's
business and maintenance of the confidence of the American people.
Any employee conduct which violates this code cannot be condoned.
Sexual harassment is unacceptable conduct in the workplace and
will not be tolerated at EPA.
Sexual harassment is a form of misconduct which undermines the
integrity of the employment relationship. All employees must be
allowed to work in an environment free from unsolicited and unwel-
come sexual overtures. Sexual harassment debilitates morale and
interferes with the work productivity of its victims and co-workers.
Sexual harassment is a prohibited personnel practice when it results
in discrimination for or against an employee on the basis of conduct
not related to work performance, such as taking or refusing to take
a personnel action, Including promotion of employees who resist or
protest sexual overtures. Specifically, sexual harassment is
deliberate or repeated unsolicited verbal comments, gestures, or
physical contact of a sexual nature which are unwelcome.
A supervisor who uses implicit or explicit coercive sexual behavior
to control, influence, or affect the career, salary, or job of an
employee is engaging in sexual harassment. Similarly, an employee
who behaves in this manner in the process of conducting agency
business is engaging in sexual harassment. Finally, an employee
who participates in deliberate or repeated unsolicited verbal
comments, gestures, or physical contact of a sexual nature which are
unwelcome and interfere with work productivity is also engaging in
sexual harassment.
Our Personnel management must be free from such prohibited personnel
practices and consistent with merit system principles, as outlined
in the provisions of the Civil Service Reform Act of 1978. All EPA
employees should avoid conduct which undermines these merit principles
At the same time, it is not the Intent of the Agency to regulate the
social interaction or relationships freely entered into by EPA
employees.
Any employee who feels victimized by sexual harassment should contact
the Office of Civil Rights to learn of the confidential counseling
services and legal recourses available within the Agency.
NOV 2 8 1986
Lee M. Thomas
Administrator
27
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.3SR
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
<4, >/ WASHINGTON. D.C. 20460
•*t PO&I
NOV 2 8 1985
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: FY 87 Affirmative Action Policy and Program Objectives
TO: Assistant Administrators
General Counsel
Inspector General
Associate Administrators
Regional Administrators
Staff Office Directors
During FY 86, we continued to make substantial progress
in improving the representation of women and minorities at all
levels of our workforce. Our data indicate that we will exceed
tne Agency's overall goal of filling 52% of our professional
and administrative vacancies with women and minorities. This
is the third consecutive year EPA has exceeded its overall
goals for women and minorities. I am particularly pleased to
note that minorities and women are making gains in Grades 13
- 15 specifically, and in supervisory and managerial positions.
In addition, EPA took positive steps to improve the planning
process for hiring, placing and advancing handicapped individuals
in our workforce.
The Agency also moved closer to full achievement of the
goals established for our upward mobility program. To date,
approximately two-thirds of the upward mobility positions are
filled. By the end of FY 87, it is expected that all positions
will be filled and each office will participate in this program.
The upward mobility program provides us a unique opportunity to
make full productive use of our staff and is an excellent
complement to the Agency's human resource development initiatives.
During FY 87, I also expect you and the managers under your
supervision to continue to place a high priority on meeting the
hiring goals that are mutually agreed upon between you and the
Director of Civil Rights. I want to place particular emphasis
on meeting our_speclfic goals for hiring minorities. In FY 86
28
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-2-
the hiring rate for minorities in general and for Blacks in
particular, was only slightly over half of what was targeted;
for Hispanics it was only a quarter of the targeted level.
Furthermore, nearly 802 of the minority hires were accomplished
by only seven offices. I am asking each of you to review
personally how well your office, region and/or laboratory
component performed in meeting the hiring goals you set in FY
86. In cases where goals were not met, Improved recruitment
and retention strategies should be implemented to correct the
problems you discover in your review.
I urge you to increase your effort to improve the
representation of women and minorities in senior grades and
supervisory and managerial positions. While we made progress
overall, one-third of our offices and regions made none.
Providing opportunities for women and minorities to prepare
for advancement to these levels is an important part of the
total human resource development efforts which the Deputy
Administrator and I strongly support.
As in our total mission of protecting the environment,
actual results are the real measure of our success. I have
attached two very important documents, the Agency's Affirmative
Action Policy and Program Objectives for FY 87 and an updated
statement of EPA's Policy on the Prohibition of Sexual Harassment
It is your responsibility to implement these policies and to
meet the program objectives which have been established. This
Is an important area of your performance, and I have asked the
Deputy Administrator to periodically review and evaluate our
progress in meeting Civil Rights objectives.
Lee M. Thomas
Attachments
29
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
^n\/ 2 o • jcr-
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: Prohibition, Prevention and Resolution of Sexual
Harassment at EPA
TO: Assistant Administrators
General Counsel
Inspector General
Associate Administrators
Regional Administrators
Staff Office Directors
Attached is the policy of EPA concerning the prohibition
of sexual harassment. I am sending a copy of it to all EPA
employees.
This statement should be posted in a prominent manner
within each major office of your organization. Each of you
should also prepare and post your own directives on this
matter.
I want to reiterate my strong personal views about sexual
harassment. It is a serious offense against the individual
victim which undermines both the integrity of the employment
relationship and the productivity of the workplace. I expect
you to implement the attached policy on sexual harassment and
to inform your staff that it is a prohibited practice and will
not be tolerated at EPA.
Sexual harassment is most effectively dealt with by
preventing its occurrence. You should ensure that appropriate
awareness training is provided to supervisors and employees
and assure employees that their right to work in this agency
free of the fear of sexual harassment will be protected.
If you require additional information regarding this issue
or need assistance in developing appropriate training for the
prevention of sexual harassment, please contact the Office of
Civil Rights on 382-4575.
Lee M. Thomas
30
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
N3V 2 8 1985
THE ADMINISTRATOR
MEMORANDUM
SUBJECT: Policy Statements on Affirmative Action and the
Prohibition of Sexual Harassment
TO: All EPA Employees
I want all members of the EPA community to be aware
of my continuing firm commitment to civil rights and equal
employment opportunity at EPA. The attached documents
reaffirm this commitment. The first states EPA policy and
establishes objectives for our Affirmative Action Program
for Minorities and Women and Handicapped Individuals during
*FY 1987. The second reiterates EPA policy prohibiting
sexual harassment. By separate memo I have advised EPA
supervisors and managers of their responsibilities in
regard to these policies.
Lee M. Thomas
Attachments
31
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
OCT 3 B86
OFFICE OF
CIVIL RIGHTS
MEMORANDUM
SUBJECT: Development of 1987 Affirmative Action Plan
FROM: Nathaniel Scurry, Director/Mf//T
Office of Civil Rights ' *^l/J
TO: Assistant Administrators
General Counsel
Inspector General
Regional Administrators
You will soon receive the Administrator's memorandum
concerning EPA's 1987 Affirmative Action Policy and Program.
Please note that it includes a statement of EPA's policy regard-
ing affirmative action for handicapped individuals as well as
for minorities and women. As you know, EPA receives guidance
from and is responsible for reporting to the Equal Employment
Opportunity Commission (EEOC) for both of these programs. We
are seeking to improve coordination of the programs, and this
joint policy issuance is the first step in that direction. The
Office of Civil Rights and the Personnel Management Division
will continue to issue separate specific guidance on developing
plans and preparing progress reports for the two programs.
This year for the first time, the Administrator's policy
statements on Affirmative Action and the Prohibition of Sexual
Harassment will be distributed to all employees. We believe
that greater awareness by all members of the EPA community will
contribute to the effectiveness of equal employment opportunity
and affirmative action at EPA.
With regard" to the Affirmative Action Plan for Minorities
and Women (AAP), the FY 87 policy memorandum confirms con-
tinuation of the basic initiatives begun during the last three
years with specific focus on developing and advancing minorities
and women as well as attracting them to the Agency. All of
these efforts will be incorporated into EPA's AAP describing
accomplishments in FY 1986 and goals and the strategy for meet-
ing them in FY 1987. This memo provides you with the schedule
for developing our 1987 AAP consistent with the policy guidance
provided by the Administrator.
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EPA is required to submit its AAP to the EEOC by December
31f 1986 for review and approval. In order to meet that dead-
line while focusing on the substantive portion of our program
(affirmative recruitment, hiring and development efforts), we
will continue to develop the AAP in two stages. First, we will
determine specific goals and then develop the complete plans
with all the documents required by EEOC. We will conduct this
two-stage operation in accordance with the attached timetable.
To assist you in developing your affirmative action goals
and plans we are providing detailed guidance and instructions
as well as comprehensive computerized workforce data reports to
key staff in your office. At•Headquarters, my staff will brief
EEO Liaisons on steps necessary to develop the goals and the
subsequent Headquarters Plan whose preparation will be coordi-
nated by the Office of Civil Rights. For-the field, my staff
is sending specific instructions to the Regional and Area
Directors of Civil Rights for development of the AAP and com-
pletion of the documents required for submission to the EEOC.
In addition my staff will conduct a series of conference calls
to provide technical, assistance and respond to questions of
staff designated to prepare the AAP documents. Special Emphasis
Program Managers can also be a useful resource in developing
goals and overall plans, as well as in outreach and recruitment
activities.
With this assistance I think you will be able to meet the
deadlines established. While they are tight, I am sure you can
appreciate that they are essential to submitting our AAP to
EEOC on time, by December 31.
Please contact me or Cecelia Scott, Affirmative Action
Program Manager, at FTS 382-4563 if you have questions or need
further information. Thank you for your continuing support and
cooperation in developing and carrying out an effective affirma-
tive action program at EPA.
Attachment
Schedule for Developing 1987 Affirmative Action Plan.
cc: Administrator
Deputy Administrator
Associate Administrators
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SCHEDULE-FOR DEVELOPMENT OF 1987 AFFIRMATIVE ACTION PLAN- (AAP)
DATE-
Octdber 10
October 14 - 17
October 23
October 24
November 12
November 26
December 3
Decenber 10
December 12
Decenber 17
Decenber 31
PROJECT
Dissemination of workforce
data reports to Headquarters
Offices, Regions, and Labs
Technical assistance via
conference calls to field and
Headquarters briefing session
* Submission of projected
vacancies and proposed
affirmative action goals
to OCR
Progress Report to Administrator
Reocmnendation on distribution
of goals to Headquarters
Offices, Regions and Tabs
* Submission of final goals
to OCR
* Submission of complete AAP
to OCR
Progress Report to Administrator
Oonpletion of Headquarters AAP
Submission of recommendations
on individual AAPs to Regions
and Labs
Progress Report to Administrator
Submission of Agency and Head-
quarters AAPs to Administrator
* Submission of all AAPs to EEOC
following notice of approval
by Administrator
WHO IS- RESPONSIBLE
Administrative Systems
Division and Office of
Civil Rights (OCR)
OCR
Assistant Administrators
General Counsel
Inspector General
Regional Administrators
Director, Office of
Executive Support
OCR
OCR
Assistant Administrators
General Counsel
Inspector General
Director, Office of
Executive Support
Regional Administrators
Area EEO Officers
OCR
OCR
OCR
OCR
OCR
Regional Administrators
Area F.TD Officers
OCR
* Documents requiring signature
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*" £S ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
,
Washington. D.C. 20460
OCT 3 B86
MEMORANDUM _ civ" mows
SUBJECT: Guidance and Instructiq^!^>r Development of
1987 Affirmative
FROM: Cecelia Scott^
Affirmative Action Program Manager
Office of Civil Rights (A105)
TO: Regional and Area Directors of Civil Rights
Attached is a document which provides specific guidance
and instructions for developing our Affirmative Action Plan
(AAP), based on EPA's 1987 affirmative action policy established
by the Administrator and the schedule outlined by the Director
of Civil Rights in his October 3 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 and your
staff in developing the AAP and in briefing managers on the
objectives for EPA's 1987 Affirmative Action Program.
We will develop the AAP in two stages: 1) Development df
goals and 2) Development of AAP documents for the EEOC. Two
dates are critical for submission of documents to the Office
of Civil Rights (OCR) in order to ensure timely development
of both Agencywide and individual component plans:
October 23 - Submission of a) projected vacancies
(including anticipated turnover) and
proposed affirmative action goals on
EEOC Form 512 and b) planned number of
Upward Mobility Program positions (both
ongoing and new) on form provided
November 26 — Submission of complete AAP for each lo-
cation as required by EEOC Management
Directive 707A
A complete schedule for development of the Agencywide AAP is
attached to the guidance. Please note on it those documents
requiring the signature of the Regional Administrator or
appropriate Assistant Administrator.
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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 EEO staff should be actively involved in
the entire development and implementation of the AAP.
To facilitate development of individual AAPs, I have
planned a series of conference calls October 14 - 17, in order
to respond to questions on the guidance and provide technical
assistance to staff assigned to prepare the AAP documents.
Please let me know as soon as possible whom you designate as
the lead person to coordinate the development of your AAP and
to act as liaison with OCR. I would also appreciate receiving
confirmation by October 10 of who will be participating in the
conference call from your location. Your lead person should be
involved if at all possible, and one additional person may also
participate. The schedule for the calls follows:
October 15
October 16
October 17
TIME
10 a.m. - 12 noon
EOT
10:30 a.m. -
12:30 p.m., EDT
LOCATION
Regions II,
III and V
Regions I, VI,
VII and VIII
PHONE*
8/382-7201
*
8/382-7319
1-3 p.m.
EDT
10 a.m. - 12 noon
EDT
Regions IX and 8/382-7201
X, Las Vegas
Region IV, RTP 8/382-7201
and Cincinnati
* Participants should call the number listed about 2 minutes
before starting time. Emergency number in case of being
disconnected is 8/382-2001.
I hope that these calls will be helpful to your staff. I
will of course be available to provide additional assistance.
Please contact me (FTS 382-4563) if you have any questions or
need further information to complete the required documents.
Thank you for your cooperation and assistance.
Attachments
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GUIDANCE AND - INSTRUCTIONS
FOR
DEVELOPMENT OF 1987 AFFIRMATIVE ACTION PLAN
GENERAL'INFORMATION
EPA's Affirmative Action Plan will be developed in
conformance with directives received from the Equal Employment
Opportunity Commission (EEOC), EPA's 1987 Affirmative Action
Policy and Program Objectives and the schedule outlined by
the Director of Civil Rights in his October 3 memo.
EPA is required to submit its Affirmative Action Plan
(AAP) to the EEOC by December 31, 1986 for review and approval.
In order to meet that deadline, EPA will develop its AAP in
two stages: 1) Development of goals and 2) Development of AAP
documents for the EEOC. Two dates are critical for submission
of documents to the Office of Civil Rights (OCR) in order to
ensure timely development of both Agencywide and individual
component plans:
October 23 - Submission of a) projected vacancies
(including anticipated turnover) and
proposed affirmative action goals on EEOC
Form 512 and b) planned number of Upward
Mobility Program positions (both ongoing
and new) on form provided
November 26 — Submission of complete AAP for each lo-
cation as required by EEOC Management
Directive 707A
DEVELOPMENT OF GOALS
Early agreement on goals is essential to assure appropriate
focus in recruitment and hiring activities. EEOC Form 512
should be submitted for this purpose to OCR by October 23,
listing on each form: a) the total number of projected vacancies
in each PATCO category under "PLANNED #", 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. In addition you should submit the
planned number of Upward Mobility Program positions on the form
provided for this purpose.
Form 512 is used to show hiring goals. Although internal
movement goals are not included in the AAP, gains made through
internal movement during the year will be credited on the
Affirmative Action Tracking Report showing gains, losses and
net gain.
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OCR will review the proposed goals to ensure consistency
with Agency policy and with overall objectives to improve
representation for each underrepresented target group. OCR
will notify each organizational component of its recommendation
by November 12.
In order to assist each component in establishing goals/
OCR has highlighted, on the appropriate EEO 50 computer report,
areas where specific target groups were underrepresented in the
component's workforce as of September 27, 1986.
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 the
organization receives the Civil Rights computer reports with
September 2J$'?data. A list of current data reports is attached.
In addition, reference is made below to the relevant data
reports which may be used to complete each EEOC Form in the
Accomplishment Report.
For purposes of EEOC's Management Directive (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. Modifications may be made in
reports submitted by the Area EEO Offices in order to reflect
the diverse locations of the small laboratories, pending agree-
ment with Headquarters OCR. As in last year's AAP, goals for'
the laboratories will be submitted through the appropriate
Headquarters office.
By November 26, 1986, each P/R Unit should 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 Adminis-
trator. All reports and updates are due at EEOC December 31,
1986.
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
include a "PER" report which combines full-time and part-time
employees. The EEO 50 and 51, Affirmative Action Tracking
Reports also provide information on all permanent employees.
These should facilitate completion of the EEOC forms.
The following EEOC forms 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.
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Accompli shment • Reports
Form 504 - Accomplishment Report Cover Sheet (CR02PER4)
Forms 505 and 505A - Change in Work Force EEO Profile
by PATCO and for Occupational Series of 100 or more
(EEO 50, CR10PER4)
Forms 507 and 507A - Distribution of EEO Groups and
Underrepresentation Indices by PATCO and Pay Level
(EEO 50, CR10PER4)
Forms 508 and 508A - Hiring Goal Accomplishments
by PATCO and for Occupational Series of 100 or
more (EEO 51 - Gains, CR10PER4 - 9/85 and 9/86)
Form 510 - Barrier Elimination
NOTES: '
1) "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.
2) Underrepresentation Indices for Forms 507
and 507A will be based on census data in EEOC's
revised "Appendix B" and instructions provided
by the Affirmative Action Program Manager.
3) When calculating Underrepresentation Indices,
always round down, e.g. 92.7 becomes 92, not 93.
4) Where an Underrepresentation Index exceeds 100,
•the actual number should be used, not "100+."
5) Form 508 will include new hires, transfers,
conversions from Other-than-Permanent positions,
and promotions into each PATCO category. This
information is reported under "Gains" on the
EEO 51 computer report.
Updates
Form 511 - Update Cover Sheet
Form 512 - Hiring Goals by PATCO
Form 514 - Projected Barrier Elimination
NOTE: Barriers in various series or PATCO categories
should be addressed on Form 514 whether or not
vacancies are projected in them.
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In addition -to the EEOC Forms, a narrative statement
should be attached to describe relevant activities in the
Affirmative Action Program that are not reported elsewhere or
require more explanation than is possible in the forms provided.
Specifically, the narrative should include a statement of goals
established for improving representation of women and minorities
in supervisory and managerial positions and a brief description
of the strategy proposed to accomplish these goals.
A statement of certification of the qualifications of
all EEO Officials must also be attached. A format to be used
for this purpose is attached.
Several documents are attached for reference in preparing
Affirmative Action Plans. For any additional information or
assistance, contact Cecelia Scott, National Affirmative Action
Program Manager, on FTS 382-4563.
Attachments:
1) Schedule for Development of 1987 Affirmative Action Plan
2) Memorandum on Development of 1986 Affirmative Action Plan (Scurry)
3) EEOC Form 512 and Upward Mobility Program Form for use in
submission of proposed goals to OCR
4) Appendix B (Revised): - Pertinent census data for use in
preparing AAP
5) Instructions: How to Figure Underrepresentation Index
6) Affirmative Action Tracking Report - Computer Reports EEO 50
and 51 dated 9/27/86
7) Set of EEOC forms prescribed for compliance with MD 707A
8) Certification of Qualifications of Principal EEO Officials
9) Appendix A: Listing of PATCO Categories By Occupational Series
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ENVIRONMENTAL PROTECTION AGENCY
PLANNING AND REPORTING UNITS
EPA OFFICE
EEOC OFFICE
Headquarters
401 M. Street, S.W.
Washington, D.C. 20460
FTS:8-382-4575
Headquarters
Region I
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
FTS: 8-223-7210
New England
Region II
26 Federal Plaza
Room 900
New York, NY 10278
FTS: 8-264-2525
Eas te rn
Region III
841 Chestnut Street
Philadelphia, PA 19107
FTS: 8-597-9800
Mid-Atlantic
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
FTS: 8-257-4727
Southeast
Region V
230 South Dearborn Street
Chicago, II 60604
FTS: 8-353-2000
Great Lakes
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Region VI • Southwest
1201 Elm Street
Dallas, TX 75270
FTS: 8-729-2600
Region V.II Mid Continent
726 Minnesota Avenue
Kansas City, KS 66101
FTS: 8-757-2800
Region VIII Rocky Mountain
One Denver Place
999 18th Street
Suite 1300
Denver, CO 80202-2413
FTS: 8-564-1603
Region IX Western
215 Fremont Street
San Francisco, CA 94105
FTS: 8-454-8071
Region X Northwest
1200 Sixth Avenue
Seattle, WA 98101
FTS: 8-399-5810
Cincinnati Area EEO Office Great Lakes
26 West St. Clair Street
Cincinnati, OH 45268
FTS: 8-684-7940
(Serves Laboratories at
Cincinnati, OH and Ann Arbor, MI)
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Las Vegas Area Office Western
P.O. Box 15027
Las Vegas, NV 89114
FTS: 8-545-2512
(Serves Laboratories at '
Ada, OK; Athens, GA; Corvallis, OR;
Duluth, MN; Gulf Breeze, FL;
Las Vegas, NV; Narragansett, RI;
and the National Environmental
Investigations Center in Denver, CO)
Research Triangle Park (RTP) Area Southeast
EEO Office
Research Triangle Park, NC 27711
FTS: 8-629-4249
(Serves Laboratories at Montgomery, AL
and RTP, NC)
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