Equal Employment Federal Aviation Administration Opportunity Commission Management Directive 715 Presented to: FAA Employees By: Yvette Aine, MD-715 Program Coordinator June 9, 2011 Date:
EEO MD-715 Developed by EEO Commission Effective October 1, 2003 EEO responsibilities under Section 717 of Title VII and Section 501 of the Rehabilitation Act Directive provides policy guidance and standards for establishing & maintaining affirmative programs of EEO EEOC MD-715 Briefing Federal Aviation 2 2 June 9, 2011 Administration
EEO MD-715 Policy I ntent Objective is to ensure that all employees and applicants for employment enjoy equality of opportunity in the federal workplace regardless of race, sex, national origin, color, religion, age, genetic information, disability or reprisal for engaging in prior protected activity. EEOC MD-715 Briefing Federal Aviation 3 3 June 9, 2011 Administration
What does MD-715 require? A Model EEO Program All employment decisions are free from “The airport runway is the discrimination Most important mainstream In any town.” -Norm Crabtree Analyze whether employment policies, procedures or practices are barriers to equal opportunity Correct identified barriers to equal opportunity Report plans and progress to EEOC annually EEOC MD-715 Briefing Federal Aviation 4 4 June 9, 2011 Administration
MD-715 Highlights Model EEO Program Part A - Section 717 of Title VII and Part B - Rehabilitation Act “The airport runway is the Most important mainstream In any town.” Non-Discrimination -Norm Crabtree Agency Self- Assessment Barrier Identification & Elimination Part C- EEOC Oversight and Technical Assistance EEOC MD-715 Briefing Federal Aviation 5 5 June 9, 2011 Administration
Six Essential Elements of a Model EEO Program 1. Demonstrated commitment from agency leadership “The airport runway is the Most important mainstream 2. Integration of EEO into agency strategic mission In any town.” -Norm Crabtree 3. Management & Program Accountability 4. Proactive Prevention of unlawful discrimination 5. Efficiency 6. Responsiveness and Legal Compliance EEOC MD-715 Briefing Federal Aviation 6 6 June 9, 2011 Administration
Essential Elements have various components by which an agency can “The airport runway is the achieve a Model EEO workplace Most important mainstream In any town.” -Norm Crabtree The following slides highlight selected components which are conducted at the corporate level EEOC MD-715 Briefing Federal Aviation 7 7 June 9, 2011 Administration
Element # 1: Demonstrated commitment from agency leadership by: Supporting corporate Model EEO Program and communicating such support Issuing written policy expressing commitment to EEO and a workplace free of discrimination EEOC MD-715 Briefing Federal Aviation 8 8 June 9, 2011 Administration
Element # 2: Integration of EEO into Agency Strategic Mission EEO integrated into Flight Plan Provide EEO Director access to senior officials for reporting on effectiveness, efficiency and legal compliance of EEO programs Management/personnel policies, procedures and practices are examined at regular intervals to assess whether there are any hidden impediments to the realization of equality of opportunity EEOC MD-715 Briefing Federal Aviation 9 9 June 9, 2011 Administration
Element # 3: Management & Program Accountability Evaluate and hold all managers, accountable for effective EEO programs Establish procedures to stop & prevent all forms of discrimination Implement effective Reasonable Accommodations procedures that comply with laws including Architectural Barrier Act Accessibility Standards Review each FAD to determine appropriateness of taking disciplinary action Ensure compliance with settlement agreements and orders issued EEOC MD-715 Briefing Federal Aviation 10 10 June 9, 2011 Administration
Element # 4: Proactive Prevention of Unlawful Discrimination On-going obligation to prevent discrimination The FAA conducts a self-assessment annually to monitor progress and identify program deficiencies and barriers EEOC MD-715 Briefing Federal Aviation 11 11 June 9, 2011 Administration
Element # 5: Efficiency The Agency maintains efficient; fair and impartial complaint resolution process and tracks complaints for significant trends Encourage the use of ADR when appropriate The Agency maintains a system that collects accurate information on Race National Origin (RNO) and disability status for employees, including applicant flow data Identify and disseminate best workplace practices EEOC MD-715 Briefing Federal Aviation 12 12 June 9, 2011 Administration
Element # 6: Responsiveness and legal compliance Agency fully complies with all EEO laws, regulations and orders Management fully and timely complies with any corrective action and relief identified in final EEOC orders or judicial decisions EEOC MD-715 Briefing Federal Aviation 13 13 June 9, 2011 Administration
I mplementation I nstructions of MD-715 Divided into 3 Sections: I. Agency Self Assessment II. Barrier Identification and Plans to Eliminate III. Reporting Requirements plus Workforce Tables EEOC MD-715 Briefing Federal Aviation 14 14 June 9, 2011 Administration
Section I : Self-Assessment Describes how programs should be structured and guidance in conducting self assessment to identify program deficiencies Emphasizes the involvement of other offices to achieve Model Program (e.g., AHR, AIO, ATO, etc.) Requires agency certification EEOC MD-715 Briefing Federal Aviation 15 15 June 9, 2011 Administration
Section I I : Barrier I dentification & Elimination What is a barrier? How are barriers identified? How are barriers addressed? Who is responsible for identifying barriers? EEOC MD-715 Briefing Federal Aviation 16 16 June 9, 2011 Administration
What is a barrier? A policy, procedure, practice or condition that limits employment opportunities for employees or applicants because they are members of a particular race, ethnic background, sex or because of a disability Three types of barriers - Attitudinal - Physical - Policy, procedure or practice EEOC MD-715 Briefing Federal Aviation 17 17 June 9, 2011 Administration
How is a barrier identified? Analyzing workforce statistics as an initial diagnostic tool which is an incomplete picture of the state of our workforce Reviewing EEO Complaints and grievances etc., for trends Conducting focus groups Speaking to stakeholders and unions Reviewing studies and employment practices with HR officials Reviewing existing workforce studies resources, e.g., Employee Attitude Survey, Exit Interview data etc. Investigating to pinpoint root cause of potential barrier EEOC MD-715 Briefing Federal Aviation 18 18 June 9, 2011 Administration
How is a barrier addressed? Devising and implementing a plan to eliminate the barrier Evaluating success of plans implemented Determining if plans need to be adjusted or if new or additional barriers exist EEOC MD-715 Briefing Federal Aviation 19 19 June 9, 2011 Administration
Who is responsible for identifying barriers? EEO Action Committee is involved in identifying overall Corporate barriers Field level managers are not required to independently identify barriers but may provide input as required by their LOB/SO as part of their official responsibility to the MD-715 points of contact for their LOB/SO All barriers and actions identified are reviewed and approved by ACR and AGC before inclusion into final report EEOC MD-715 Briefing Federal Aviation 20 20 June 9, 2011 Administration
Section I I I : Reporting Requirements New race/ethnic categories Certification of Compliance Annual EEO Status Report includes actions to address and eliminate barriers Workforce Tables for agency general workforce and for people with disabilities EEOC MD-715 Briefing Federal Aviation 21 21 June 9, 2011 Administration
New Race/Ethnicity Categories H - Hispanic/Latino W - White (Non-Hispanic) B - Black or African American (Non-Hispanic) AI AN - American Indian or Alaska Native (Non- Hispanic) A - Asian (Non-Hispanic) NHOPI - Native Hawaiian or Pacific Islander (Non- Hispanic) 2+ - Two or more Races EEOC MD-715 Briefing Federal Aviation 22 22 June 9, 2011 Administration
FAA Mission Critical Occupations Computer Specialist Air Traffic Controllers 2152 334 Air Transportation Miscellaneous Specialist 2101 Administration and Program 301 Aviation Inspectors 1825 Management Program Analysis 343 Engineers 800 series EEOC MD-715 Briefing Federal Aviation 23 23 June 9, 2011 Administration
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