Ensuring Workplace Safety Through a Model EEO Program

By Michael Rhoads, June 21, 2022

I recently attended a meeting of the Federal EEO and Civil Rights Council where Dexter Brooks, Director of Federal Sector Programs of the Office of Federal Operations at the EEOC, explained how to make your workplace safer. The tools are already available. You should have the infrastructure in place, but here’s how to update and fine-tune your program to make it a safer space for all employees.

This may or may not come as a surprise: The top issue in workplace safety is harassment. It is the fastest growing issue in EEO complaints with over 50 percent of complaints containing a harassment component, according to Brooks.

Your agency recently submitted a self-assessment of its anti-harassment policy. There should already be rules set up for employee conduct inside and outside the workplace. Part of the self-assessment addressed areas of support for employees who experience sexual assault, domestic violence, and stalking.

To successfully implement your agency’s anti-harassment policy and advance workplace safety, Brooks suggested focusing on the six core principles of a model EEO program. I found NASA’s Office of Diversity and Equal Opportunity at their Langley Research Center to have a handy guide to follow.

The 6 Core Principles

1 – Ensure your agency’s leadership is committed to the EEO program. Agency leaders should take a top-down approach when communicating the EEO program’s goals. The agency head should then issue an EEO and anti-harassment policy statement on an annual basis.

2 – Integrate EEO into the agency’s strategic mission. The Director of EO (or DEI) should have regular access to senior management. Also, managers and employees should be directly involved in implementing your agency’s Title VII and Rehabilitation Act Programs.

3 – Ensure program accountability. Managers and supervisors play a big role in this part of the process. While the agency establishes the procedures to prevent all forms of discrimination, it falls on the managers and supervisors to be the agency’s eyes and ears. Additionally, the agency should ensure that reasonable accommodations and personnel policies are clearly defined.

4 – Be proactive in preventing unlawful discrimination. Agencies should conduct a self-assessment of their EEO programs on at least an annual basis. This should include a barrier analysis. Think of not only the physical barriers, but the cultural barriers that exist. For example, first generation professionals might not have the same resources available to them that others do. After the analysis is complete, act on the information, and come up with a strategic plan to eliminate those barriers identified.

5 – Find an efficient way to deal with EEO issues. Data is the foundation on which problems can be solved. If you don’t have quality data, it’s like flying a plane through clouds without flight instruments – eventually you’ll crash. The data you’ll need to collect specifically will be related to hiring, your current workforce, and EEO complaints. Additionally, complaint resolutions and alternative dispute resolutions processes should also be checked for efficiencies as well.

6 – Be responsive and legally compliant. The laws in question are Title VII and the Rehabilitation Act. Also included in legal compliance are EEOC’s regulations, orders, and other written instructions. Each year, report your program’s accomplishments to the EEOC. Be sure to comply with any final EEOC order for corrective action and relief. FELTG has worked with many agencies when the EEOC has ordered compliance training at the conclusion of a complaint.

For more information on how your agency can improve on its EEO program, FELTG will be hosting our EEOC Law Week from September 19-23, from 12:30-4:30 ET each day.  Meanwhile, stay safe, and remember, we’re all in this together. Rhoads@FELTG.com