Admittedly, this step was first developed when Internet recruiting was less prevalent. While it is efficient and convenient to mass mail lots of different diversity sites to try to reach a broad, diverse, qualified candidate pool in terms of compiling your Step 2 list, I would encourage you to try to identify even just a few sources among that list that might be local to some of your locations, obtain a contact person's email or information, try sharing with them any information about job training programs that you are developing, and maintain records of the emails. If you are a Circa client, you can find out who the ESDS contact is. It is harder during the pandemic to interact meaningfully with qualified construction candidates, but the OFCCP will be paying attention to your efforts. The OFCCP appreciates meaningful, quality contacts that result in diverse pools. They are not counting how many sources your jobs went to. If there are high schools or trade schools for particular crafts that have provided quality candidates for training opportunities in the past, see if you can ensure you're giving their career or outplacement offices the heads up about your upcoming job training programs. Give the ESDS contact the heads up, too. I don't intepret the Step to mean that every single recruiting source gets the job training heads up email. Go for quality, not quantity. And keep the records.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.