To account for the temporary nature of the construction workforce, OFCCP does not require construction contractors to develop a written affirmative action program. Instead, the federal regulations have established 16 affirmative action steps and utilization goals based on civilian labor force participation rates.

The utilization goals are expressed as a percentage of the hours worked by the contractor? aggregate workforce in each trade on all construction work performed in a specific geographic area, which incorporates all projects: Federal, federally assisted, and non-federal.

DHRD is able to establish a system for each company based on their employment policies and practices and our experience with the Federal Regulations to perform the required 16 Affirmative Action Steps and all obligations associated with the regulations. This includes, but is not limited to the following:

• Recommendations for compliance with the 16 Affirmative Action Steps
• Monitoring workhour utilization by craft, race, and gender for each SMSA or Economic Area
• Establish EEO/Anti-Harassment Policies
• Compensation plans/review
• Establish applicant flow, hire, promotion, termination, and training logs and ensure compliance with federal regulations
• Conduct adverse impact analysis
• EEO-1 Reports
• I-9 Forms
• VETS-100 Report
• Training of managers regarding responsibility for EEO and Affirmative Action and harassment in the workplace
• Training of employees
• Acceptable employment applications
• Compliance with the Vietnam Era Veterans Readjustment Assistance Act of 1974, as amended (38 U.S.C 4212 or VEVRAA) (Federal contracts or subcontracts)
• Compliance with Section 503 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 793) (Federal contracts or subcontracts)
• Conduct mock audits
• Perform scheduled analysis of reports
• Assist in recruiting requirements
• Conduct complaint investigations and provide recommendations
• Review existing affirmative action systems and provide recommendations
• Translation services (English to Spanish)
• Provide answers to your questions