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Unless you are a construction contractor (and if you are, please ask the question again and say so) I assume your question refers to performing the Availability Analysis that the regulation (41 CFR 60-2.14) requires be performed for EACH Job Group and SEPARATELY for minorities and women. While the OFCCP annually established the percentage "benchmarks" for the hiring of veterans and for hiring of individuals with disabilities, the contractor must establish its own annual AAP Goals for women and minorities using the method mandated by regulation. The regulation requires the contractor to consider at least two factors; the first one involves estimating the percentage of minorities and of women who have the requisite skills who are outside the AAP workforce (external availability). The other factor is concerned with internal availability. Your question relates to Factor 1 in determining estimated availability. Factor 1 is the percentage of women and the percentage of minorities -- having requisite skills -- in the "reasonable recruitment area" So the answer to your question is: IT DEPENDS! First, it depends on what the "reasonable recruitment area" is for EACH particular Job Group. It's unlikely that this geographic area, whether it is Oregon or perhaps the Pacific Northwest Region, or even as narrow as the immediate labor market surrounding the facility, or perhaps as wide as the entire United States is the same for each APP Job Group. Think: entry level labor or clerical positions versus Treasurer. Or Physicists versus Accountants. How far afield must the contractor typically seek qualified workers for the positions in the Job Group? Questions to ask yourself are: how many of the current incumbents in the Job Group were hired locally? For what jobs do we pay relocation expense? Does this Job Group include positions that we sometimes/always/never outsource to search firms? Factor 1 also depends on the skills necessary for each Job Group. Contractors must use the most recent and most accurate statistics available. For each of many different geographical areas (i.e. “reasonable recruitment”) in the country, data from the last U.S. Census are available showing the percentage of women and of minorities who were working in jobs that vary from Boilermaker to Attorney to Landscaper, to Teacher, etc. -- a variety of occupations that are the closest proxy we have for “requisite skills”. A state job service may also provide statistical data, possibly more current but typically in much broader occupational groupings. The availability of minorities, regardless of skills, may be different in Oregon than in Mississippi – or Vermont. And, regardless of where the contractor recruits, the availability of women Carpenters is probably quite different than the percentage of women having requisite skills as Accountants. Consequently, the AAP writer must have knowledge of and take care in identifying the “reasonable recruitment area” separately for EACH Job Group. [ESB Note: Estimating availability is WILDLY speculative. Among other things, the very best available data available – which is not necessarily very good -- will always be HISTORICAL although an AAP Goal is PROSPECTIVE. And, census data comes in only a few hundred occupational categories when in American workplaces there are thousands and thousands of very different jobs and job requirements. For example, with the possible exception of the college degree, for even the quite narrow census occupational category of “Electrical Engineer” the “requisite skills” are very different for such engineers working in electric power companies and those working in manufacturing.] Factor 1 deals with external availability. Factor 2 deals with the estimated INTERNAL availability of minorities and women who might be promotable, transferrable, or trainable to move INTO (not within) the Job Group whose availability is being analyzed. [ESB NOTE: In this context “internal” means within the specific AAP workforce; not the entire company.] Remember also, this calculation is an annual exercise and determines the annual percentage goal, if any, for the upcoming AAP Year only. It may be that only when estimating internal availability of minorities and women for a Job Group of “Journeyworkers” will a contractor have such accurate data as the percentage of minorities and women in the final year of training in its Job Group “Apprentices”. More typically, the contractor would use the incumbency rate of women and minorities in whatever job(s) or Job Group(s) “feeds” the higher-level Job Group for which availability is being estimated. [ESB NOTE: VERY often the manner in which Job Groups are designed (including, sometimes even especially, those encouraged by OFCCP compliance officers!) creates significant challenges in estimating availability. This has a “ripple effect” on both the comparison of incumbency to availability and the reasonableness of/ability to meet goals. The availability percentage will determine not only IF a goal must be established (i.e., if the difference between incumbency of minorities and/or women in the Job Group is "less than reasonably expected") but also the SIZE of the hiring/selection rate goal if one is, in fact, required.] I’ll expand my answer to briefly address some other mandatory considerations in the estimating of availability of minorities and women for each AAP Job Group. The OFCCP regulation is quite detailed in its expectations of the rigor with which contractors will perform this estimate of availability. The applicable OFCCP regulation imposes considerable structure on how to arrive at what will always be only an “estimate” of prospective availability for the upcoming AAP Year. For example, if in a single Job Group there are multiple jobs with different "requisite skills" (a very common situation, particularly in a small workforce) the contractor must give different arithmetic weight to the varying availability percentages else it either underestimate or overestimate “availability” of minorities and women for the entire Job Group. See 41 CFR 60-2/14(g). This “weighting” is used to arrive at a “composite availability” for the Job Group. Typically, this is done using a special software application but it IS doable (if tedious!) manually. For example, and very simplistically, if the contractor has established a Job Group of "Professionals" (I hope it hasn't, that's much too broad but it does happen) and the Job Group has 40 incumbents of which 36 are Nuclear Engineers (an availability of women in the recruiting area of 5%), two incumbents is an accountant (for which female availability is 50%), and two are Human Resources Specialists (for which Factor 1 availability of women is 50%), one may NOT simply add together those percentages (105%) and divide by 3 to arrive at the availability of women for the Job Group. The resulting estimated availability of 35% women for this theoretical Job Group is demonstrably inaccurate! What good faith effort could possibly be expected to produce an applicant pool of 35% women for vacancies for Nuclear Engineers? Need I add that the flip side of this situation would be equally intolerable: the OFCCP would certainly challenge an understated availability of women and minorities arrived at by combining in a Job Group job titles that are similar in EEO-1 code (NOT a regularly design criterion!) but not similar in “wages, content and opportunity”, the latter of which ARE the regulatory design criteria. To be consistent and by inference if not regulation, one must also be able to justify what weight it has given Factor 1 versus Factor 2 in the overall estimate of availability, as well as any other situations where there are multiples, i.e. availability percentages of women and minorities in multiple Feeder Jobs/Job Groups or multiple “reasonable recruiting areas” should also be “weighted”. With respect t
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