Sheet Metal & Air Conditioning Contractors’ National Association

SMACNA Providing Input to Federal Compliance Office

The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) is asking for input from contractors or their representatives in areas where further guidance on affirmative action and equal employment opportunity (EEO) obligations through anonymous opinion letters would benefit federal contractors. SMACNA’s Labor Relations Department is drafting input to submit to the OFCCP on members’ behalf.

The OFCCP uses these opinion letters to provide additional compliance assistance and guidance on the Office’s laws and regulations concerning affirmative action and discrimination. Opinion letters often provide significant insight into the OFCCP’s views on how a rule operates in real-life scenarios, because opinion letters include the application of rules and regulations to a particular set of facts.

The OFCCP is responsible for oversight of federal contractors’ compliance on affirmative action obligations and prevention of discrimination on the basis of race, color, sex, sexual orientation, gender identity, religion, national origin, disability, or status as a protected veteran.

The request for more input is part of the OFFCP’s Directive (DIR) 2019–03, which outlines the steps it intends to take to enhance the agency’s existing help desk. One step is to incorporate opinion letters for fact-specific guidance about the Office’s jurisdictional coverage, regulations, and policies.

SMACNA’s Labor Relations Department is currently drafting input to submit to the OFFCP that requests additional guidance on the issues of mandatory paid sick leave, EEO requirements where an employer exclusively uses a hiring hall, and additional affirmative action requirements.

Members who would like to provide input on EEO affirmative action or prevention of discrimination are urged to contact SMACNA’s Labor Relations Department at

Members may read the OFCCP Directive (DIR) 2019–03 at