8/13/2019 Letter to Subcommittee on Workforce Protections Hearing on Examining Recent Actions by the OFCCP 12.4.13

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LEGAL momentum

Eliabeth L. Gnyer, Pres/der,Legal Morentum

BOARD OF DIRECTORS

Chain Linda A. WillettHoizon Blue Cms Blue Shieldof New Je@y

FiEt Vice Chair: Ralph l. Knowles, Jr.Doffamye S hie lds Ca nfie Id& Knowles LLC

Vice Chair: Debonh L. RhodeYale Law School

TEaauer: Suiatha A. SrinivasanGoldman, Sachs & Co-

Secretary: BEndG StellingsCatalyst lnc.

GeneEl Counsl: Jay W. WaksKaW Scholer LLP

At Large: Elizab6th J. CabEaerUeff, CabaeL Heimann& Eemsbin LLP

Sablne Chalme6Anheuser-Busch lnBev

Kim GandyNational Netwotk to End DomeelicViolen@ (NNEDV)

Stephanie G@rgeFamt President ol People Magazine, lnStyle, Real Simple and EssereJennifer Choe GrcvesWodd Logistics Council Developrent

Matthew S. KahnGibson, Dunn & Crutcher LLP

Robert M. KaufmanPaskauer Rose LLP

SuBan J. KohlmannJonner & Block

Susan B. Lindenauer

The Legal Aid Society (Etired)Stephanie A. SheridanSedgwick LLP

Marissa C. WeselySimpson Thachet & Baftleft LLP

Laua A. WilkinsonWeil, Golshal & Manges LLP

G. Elaine WoodAlvaez & MaMlLoria B. Yeadonlntelleclual VentuEs

HONORARY DIRECTORS

Muriel Fox, Chair

Barbara M. Cox

Etta FroioWoffi o's Wea r Daily (retiEd)

Li6a Sp@htManatt, Phelps & Phiilips, LLP

'O rg a n izati o na I atri ati on s fo tputposes of idenlifrcalion only.

The Hon. fohn Kline, Chair House Committee on Education & the WorkforceThe Hon. George Miller, Ranking Member, House Committee on Education & the

WorkforceThe Hon Tim Walberg, Chair, Subcommittee on Workforce ProtectionsThe Hon. foe Courtney, Ranking Member, Subcommittee on Workforce

Protections2181 Rayburn House Office BuildingWashington, DC 20515

Re: Hearing on Examining Recent Actions by the Office of Federal ContractCompliance Programs.

December 3,2013

Dear Chairman Kline, Ranking Member Miller, Subcomm. Ch. Walberg &Subcomm. Chair Courtney:

I write to provide Legal Momentum's views for the record and in conjunctionwith the hearing, Examining Recent Actions by the Office of Federal ContractCompliance Programs. Legal Momentum is the oldest women's legalorganization in the country. We devote significant resources to improving accessto nontraditional employment and apprenticeship and training opportunities forwomen, and with Wider Opportunities for Women, we co-chair the National TaskForce on Tradeswomen's Issues, which unites local, regional and nationalexpertise and action to support tradeswomen and women who want access tothese occupations.

One of our primary areas of concern is enforcement of Executive Order 71246,which bans employment discrimination by government contractors on federaland federally assisted construction sites. The Order was revised in 1978 becauseof the almost total exclusion of women from [construction] employment. Thesame year, the regulations governing registered apprenticeship programs werealso revised to establish specific affirmative standards for women, who numberedbetween Lo/o and3o/o of apprentices in the skilled construction trades.l Weapplaud Director Shiu for the work that she and her staff have done to ensure thatfederal contractors comply with the requirements of E.O.11246. Women's access

' 43 F.d. Reg. 20769 (May 12,1978)

Headquarters: 395 Hudson Street, 5th Floor, New York, NY 10014 212.925.6635Policy Ofiice: 1101 14th Street. NW, Ste 300. Washington, DC 20005 202326.0040

8/13/2019 Letter to Subcommittee on Workforce Protections Hearing on Examining Recent Actions by the OFCCP 12.4.13

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to these high-wage career opportunities face on-going barriers that include gender stereotypingand other forms of discrimination including barriers to training and hiring and unfair jobassignments. Women need the OFCCP to help federal contractors address these issues andchange the traditional operating procedures to offer all who want these jobs real equalopportunity.

Additionally, we are fully in support of the recently revised rules re: Section 503 of theRehabilitation Act of 1973 and the Vietnam Era Veterans' Readjustment Assistance Act of 7974(VEVRAA). We applaud the new Section 503 rules, which set out a hiring goal that 7o/o of federalcontractors and subcontractors of each job group in their workforce be qualified individualswith disabilities. We also support the aspects of the rule that specify actions contractors musttake with respect to training and recruitment, record keeping and policy dissemination. Theseprovisions are similar to those that promote workplace equality for women and minorities, andhave long been in place. The new VEVRAA rule makes clear job listing and subcontractrequirements, and strengthens accountability and record-keeping requirements, therebyenabling contractors to assess the effectiveness of their recruitment efforts, These revised rules

ensure that federal contractors offer our veterans and people with disabilities access tomeaningful opportunities for work.

Taken together, the continued enforcement of E.O. Lt246, along with implementation andenforcement of the new rules regarding Section 503 and VEVRAA will ensure that federalcontractors can enhance their ability to attract, train, and hire veterans, women, people of colorand people with disabilities. It will also buttress the access of these groups to positions thatprovide economic security and help strengthen our economy. We feel that these standards arefair and encourage employers to both deepen and broaden the talent pool of those eligible for,and capable of filling these contractor and subcontractor positions. The use of affirmative actionand efforts to ensure equal employment opportunities, particularly for underrepresented

groups, is of paramount importance and we fully support the efforts of OFFCP and theDepartment of Labor in this regard.

Thank you for the opportunity to provide this testimony. We look forward to continuing to workwith you on these and other matters.

Sincerely,

Vice-President for Government Relations