If a CO’s review of the contractor’s EEO-1 job category data shows substantial disparities in the representation of a particular race or ethnic group in the workforce as a whole, or in their distribution among job categories, the review of the workforce analysis should include a focus on that race or ethnic group especially in those job areas where a CO observed disparity.
For example, if category data show that whites and Hispanics were concentrated in the Laborers category, poorly represented in Operatives and absent in Crafts, the CO’s review of the workforce analysis must:
- Specifically identify the types of blue-collar jobs in which whites and Hispanics are employed; and
- Determine whether these jobs fall into lines of progression, or departments or units, or both, that tend to inhibit progression to Operatives and Crafts, etc.
Even when a CO does not observe these disparities in the initial category screen, the CO must be alert for indications of potential problems in the distribution of the particular racial or ethnic groups while reviewing the organizational profile. This diligence is especially necessary if the labor area has high representation of more than one race or ethnic group, or the general employment patterns in the industry involved differ among specific race or ethnic groups. It is worth noting that both situations may exist simultaneously and could give rise to indicators of a potential problem.