OFCCP doesn't have specific naming conventions in its regulations regarding race and ethnicity that federal contractors and subcontractors are required to use. However, OFCCP uses the following terms in its regulations in regard to race and ethnicity and expect employers to collect demographic data according to these categories: Blacks Hispanics Asians/Pacific Islanders American Indians/Alaskan Natives Whites Note that unlike EEOC, OFCCP's regulations do NOT have a separate category for Hawaiian Natives/Pacific Islanders and do NOT have a category for persons who are two or more races. OFCCP issued a directive in 2008 that allows federal contractors and subcontractors to collect demographic data and prepare statistical reports using EEOC's race and ethnicity classifications, but OFCCP has never formally changed its regulations to match EEOC's classifications. From our experience, OFCCP has not had a problem when federal contractors or subcontractors use naming conventions for the categories above that appropriately represent the category. Thus, it should not be a problem to have an HR system that refers to "African Americans" rather than "Blacks" or that refers to "Native Americans" rather than "American Indians/Alaskan Natives." Where OFCCP might have a problem is if your system creates new or different categories than the five categories used by OFCCP or the seven categories used by EEOC. For example, if your system has a category for Asians from the Indian Subcontinent, a separate category for Asian for the the Eastern part of Asian, and a third category for Hawaiian Natives/Pacific Islanders, OFCCP might have a problem as it recognizes these first two categories as members of one class for reporting purposes. As another example, if your system has a category for Asians from the Middle East who are counted as minorities in various reports, OFCCP might have a problem since Asians from the Middle East are typically counted as white. Thus, the naming conventions you use are less important than have categories that conform to OFCCP's expectations.
