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Client Alert

OFCCP Proposed Parts 60-1 and 60-2 Rulemaking: A Wolf in Sheeps Clothing

May 01, 2000

By Paul Hastings Professional

On May 4, 2000, the Office of Federal Contract Compliance Programs at long last published its Notice of Proposed Rulemaking, proposing farreaching and substantial changes to 41 CFR Parts 60-1 and 60-2. Part 60-1 regulations govern, among other things, record retention issues. Part 60-2 regulations govern the construction, implementation and maintenance of affirmative action plans for government contractors. Though heralding its proposal as a benefit to contractors due to the simplification of the requirements of an affirmative action plan structure, and the simplification of the required annual utilization analysis of women and minorities, we believe the proposal may create many new burdens and hazards for contractors.

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