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Multiple Establishments for AAP purposes

Anonymous - Sep 05, 2017
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I’m trying to find guidance on how to determine if we have multiple establishments for our Affirmative Action Program. I’ve read that any location with 50 or more employees needs its own program, but I’ve also read that if the locations are in the same labor market or recruiting area that they can be included in the same plan.

Are there any rules that define how a labor market is determined for a location? For example, I assume that if we have multiple physical locations in the same city then it would be appropriate to combine those locations in the same AAP. If we have over 50 employees in both Buffalo, NY and New York, NY could they be considered in the same labor market of New York state, or do we need to go by the metro-areas?

1 Answer

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President and CEO, HR Unlimited, Inc.

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Member Attorney, Roffman Horvitz, PLC

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President, Carla Irwin & Associates, Inc.

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Board Member, Circa

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President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

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Managing Attorney, Roffman Horvitz, PLC

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Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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