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AFFIRMATIVE ACTION PLAN
2008-2013
Note: You may download an MS Word copy ZSD Affirmative Action Plan
Board of Directors
Chairman Barrie Carpenter
Vice Chairman Jeff Brady
Members Dennis Jones Darrin Belton Sandy Adams
Superintendent Kevin McKay
TABLE OF CONTENTS
TOPIC INDEX PAGE NUMBER
Board of Directors 2 Table of Contents 3 Introduction 4 Reaffirmation of Affirmative Action Policy 5 Authority 6 Purpose 6 Dissemination of Policy 6 Internal Dissemination 6 Internal and External Dissemination 7 Responsibilities for Implementation and Evaluation 8 Internal Audit and Monitoring System 9 Definitions 9 Underutilization Analysis 9 Table 1 Summary of Available Minorities/Women in Employment Pool 10 Table 2 Summarization of Ethnic and Gender Composition, ZSD #205 11 Salary Ranges 12 Numerical Review Analysis 13 Marital Status, Age 13 Persons with Disabilities 13 Vietnam-Era/More Recent Military Action Veterans 13 Sex, Race, Creed, Color, National Origin 13 Utilization Analysis for Ethnic and Gender Composition 13 Identification of Underutilization 15 Table 3 Underutilization Analysis 15 Problem Area Identification and Goals 20 Training and Advancement 21 Supportive Systems 21 Recruitment of Employees 21 Reduction in Force 22 Conclusion 23 Appendix A – Identification of Affirmative Action Officer 24 Appendix B – Affirmative Action Policy 25 Appendix C – Pre-Employment Inquiry Guide 27 Appendix D – Instructions for Performing a Utilization Analysis 32 Using the 4/5 or 80% Rule 32
INTRODUCTION
This is the Affirmative Action Program for the Zillah School District No. 205. It is utilized as an opportunity to measure progress and to reaffirm our long-standing policy and commitment to equal opportunity in employment. We believe education enhancement requires consistently fair and equitable educational and employment practices without regard to age, race, creed, color, religion, national origin, handicapping condition, marital status, sexual orientation, or sex. For this reason, the District seeks to employ and promote individuals that represent diverse talents, contributions, abilities and experiences representative of our society and that are essential to a quality educational program.
The Affirmative Action Plan presented here is designed for the years 2008-2013. Although the plan covers a five-year period, it is recognized that, to be effective it will require continuous evaluation and revision to correct disparities in the utilization of employees where it may exist in the Zillah School District’s work force. Modifications due to decisions by state and federal courts will also be ensured.
The basis for analysis in this plan involves a comparison of the Zillah School District’s minority staff in various job categories, to the percentage of minorities in the available labor force. Also, the basis for the analysis of gender balance in this plan is the proportion of men to women in the available labor force for various job categories.
REAFFIRMATION OF POLICY
The Zillah School District No. 205 is committed to undertake Affirmative Action that will allow effective, Equal Employment Opportunities for staff and applicants. In addition to a review of current programs, such affirmative action shall also include recruitment, selection, training, education and other programs.
This program is a directed, good faith effort to provide equal opportunity in all aspects of employment. It is a comprehensive and planned effort by the Zillah School District to:
¨ Reaffirm the Zillah School District’s policy statement. ¨ Describe policy dissemination and establishment of responsibilities. ¨ Identify barriers in the personnel management system that may limit the ability of applicants and employees to reach their full potential. ¨ Implement programs that will accelerate progress.
The Affirmative Action Plan specifies the personnel procedures to be followed by staff of the Zillah School District and shall ensure that no such procedures discriminate against any individual. Reasonable steps shall be taken to promote employment opportunities for the classes that are recognized as protected groups; aged, handicapped ethnic minorities, and women.
This policy, as well as the Affirmative Action Plan, regulations and procedures developed, shall be disseminated widely to all staff, interested patrons and organizations. Additionally, the Zillah School District’s commitment to avoiding discrimination in the hiring and promotion of disabled persons, and persons over age forty is reaffirmed. The purpose of these commitments is to ensure the absence of discrimination in employment practices. Each employee of the Zillah School District involved in the recommendation of hiring or promotion must be committed to ensuring that the recommendation is made without discrimination. It is the responsibility of each individual manager to promote a strong commitment to Equal Employment Opportunity at his/her work site and throughout the Zillah School District. Progress under this policy shall be reported annually to the Board of Directors.
Kevin McKay, Superintendent Barrie Carpenter, Board Chairman
AFFIRMATIVE ACTION PLAN
AUTHORITY
School districts in the state of Washington are required by WAC 392-200-005 to establish and implement Affirmative Action programs that are designed to “eliminate discrimination on the basis of sex, race, creed, color, national origin, marital status, age, or for presence of any sensory, mental, or physical handicap.”
PURPOSE
It is the purpose of the District’s Affirmative Action Program to promote, monitor, and maintain the District’s affirmative action and equal employment opportunity policies. These policies provide for equal employment opportunities for all employees and applicants for employment without unlawful discrimination on the basis of race, color, creed, religion, age, sex, ethnicity, national origin, veteran status, marital status, or the presence of a sensory, mental or physical disability, and promote diversity in the district’s workforce.
It is also the purpose of the District’s Affirmative Action Plan to identify at all levels of the workforce, area of underutilization of racial minorities and women. This Plan is designed to promote outreach, recruitment, training, and education efforts intended to expand the pool of applicants in the relevant labor area having the requisite qualifications to perform the positions included in the job group.
This Plan advances equal opportunity without preferential treatment on the basis of race, gender, ethnicity, or national origin. This Plan is also designed to ensure that the District’s policies are properly implemented without unlawful discrimination on the basis of race, color, creed, religion, age, sex, ethnicity, national origin, veteran status, marital status, or the presence of a sensory, mental or physical disability. Dissemination of Policy
It is the responsibility of the Superintendent of the Zillah School District, or a designee, to inform all applicants for employment, all current employees, all persons responsible for hiring within the Zillah School District, all employee associations and all Zillah School District contractors and subcontractors of its commitment to Equal Opportunity Employment. To ensure that all employees, applicants for employment, and others are aware that Zillah School District No. 205 is an Equal Employment Opportunity/Diversity Employer; and to ensure that all personnel are fully apprised of the district policy, the following actions have been taken and will continue to be undertaken:
A. Internal Dissemination
1. Equal Employment Opportunity and Staff Diversity is referenced in District correspondence, employee bulletins, reports, and manuals. 2. Supervisory meetings will be conducted on an annual basis, which explain the intent of the District’s Affirmative Action program and diversity policy as well as each individual’s responsibility for effective implementation. 3. Employees will be notified of the existence of the District’s EEO policy and diversity program through general meetings, supervisory and staff meetings, and through the Superintendent’s memo. Employees are advised that all aspects of employment, including job opportunity, training, programs, and social events, will be available to all without regard to age, race, color, disability, religion, sex, national origin or Vietnam veterans. Additionally, employees will be advised to contact either their supervisor or the Superintendent concerning problems that they have of a discriminatory nature. 4. The EEO policy and diversity program will be communicated to applicants included in new employee orientation and management training programs. 5. All employee unions and appropriate bargaining groups will be notified of the District’s policy and diversity program and their cooperation solicited. 6. A nondiscrimination clause will be included in all bargaining agreements, and all contractual provisions will be reviewed to ensure that they are nondiscriminatory. The top official in each bargaining group will be informed by letter of the policy and his or her cooperation will be requested. 7. Articles covering diversity progress will be covered in the Staff Bulletin on an annual basis. 8. The Zillah School District’s policy manual will document the procedures for prompt, fair and impartial consideration of complaints of discrimination. 9. The Zillah School District will assure that appropriate steps are taken to comply with the Title IX regulation, prohibiting sex discrimination in education and employment; and section 504 of the Vocational Rehabilitation Act of 1973, prohibiting discrimination on the basis of physical, sensory or mental handicaps in education and employment. 10. The Zillah School District will assure compliance with state laws established to eliminate sex discrimination in the public schools. 11. Copies of the 2008-2013 Affirmative Action Plan will be distributed to all pertinent organizations, agencies and people within and outside the Zillah School District, such as: ¨ The Board of Directors ¨ All Zillah School District Administrators ¨ All Zillah School District building sites ¨ All Zillah School District employee associations ¨ All Zillah School District employees, upon request ¨ The Office of the State Superintendent of Public Instruction 12. The policy of Equal Employment Opportunities and federal and state posters prohibiting discrimination is to be posted on bulletin boards at all Zillah School District building sites.
B. External Dissemination
1. The Human Resources Department will continue to communicate to prospective employees that the District is an Equal Opportunity/Diversity Employer and will especially invite protected group members to apply. 2. The District will incorporate the Equal Employment Opportunity/Diversity clause in all purchase orders, leases, contracts, and other pertinent documents.
Responsibilities for Implementation and Evaluation
The following employee is responsible for the district’s Affirmative Action program:
Kevin McKay, Superintendent Zillah School District No. 205 213 Fourth Ave., Zillah, WA 98953 (509) 829-5911
The Superintendent has the overall responsibility for the development, implementation, coordination and monitoring of the affirmative action program. He/she will provide leadership and guidance to all administrators, supervisors, and personnel in the conduct of their employment practices to assure conformity with relevant federal and state laws and regulations and Zillah School District policies.
The Affirmative Action Coordinator is charged with the responsibility of aiding in the development and implementation of an effective affirmative action program, ensuring full compliance with Equal Employment Opportunity requirements and will advise the Superintendent and/or the Board of Directors of Equal Opportunity matters, as required.
The Affirmative Action Coordinator will:
1. Review the Affirmative Action Plan annually to ensure full compliance with Equal Opportunity Employment throughout the Zillah School District, monitor and evaluate the Affirmative Action Plan’s accomplishments and prepare memoranda to specify responsibilities and proposed actions as required by this Affirmative Action Plan. 2. Work with administrators and employees in the district to assure understanding and support for the program. 3. Assist program managers in carrying out their responsibilities for implementation of the program. 4. Report to the Board of Directors on the specific progress of the affirmative action program. 5. Maintain a continuing review of all aspects of the district’s personnel system to detect illegal or improper practices, which impede the employment or advancement of members of minority groups or women and to modify these practices when necessary. 6. Establish specific training, recruiting, hiring, and selection processes necessary to accomplish the goals and objectives of the program. 7. Ensure that the Human Resource Services Department will be responsible for documenting compliance of personnel practices that include an annual statistical analysis and update of employment data to measure the effectiveness of the Affirmative Action program and to identify the areas of imbalance, if and where present. 8. Ensure a record system will be maintained by the Human Resource Services Department that collects data on the Zillah School District employees in the areas of race, sex, age, handicapping conditions and veteran status, for all job categories. 9. Ensure that a nondiscrimination clause is included in all bargaining agreements, and review all contractual provisions to ensure they are nondiscriminatory. Each Representative of the Zillah School District’s Collective Bargaining Units will be informed by a letter of the Affirmative Action policy, which will be a request for his/her cooperation. 10. Coordinate a cultural diversity, equity and non-discrimination training will be held every three years for all administrative personnel. 11. Ensure that the Zillah School District’s Equal Employment Opportunity policy and all posters required by law will be conspicuously posted on all building bulletin boards located in staff lounges and the administration lobby areas.
Questions regarding Affirmative Action should be directed to the Superintendent of Zillah School District, 213 Fourth Ave., Zillah, WA 98953, (509) 829-5911.
INTERNAL AUDIT AND MONITORING SYSTEM
To ensure the implementation and success of the Zillah School District’s Equal Employment policy, the Human Resource Services Department will maintain a record system that will monitor the plan in the following manner:
A. Collect, recall, and display facts on the Zillah School District employees in the areas of race, sex, age, disabling conditions and veteran status for all categories. B. Collect, recall and display facts on hiring, promotion, retention and other personnel actions within the Zillah School District, including work force composition by race, sex, age, disabling conditions and veteran status. C. Collect, recall, and display facts on applicant data by job, race, sex, age, disabling, conditions, veteran status and geographic location.
The Affirmative Action Coordinator will evaluate the effectiveness of the plan and recommend changes to the Board of Directors through the Superintendent. Changes mandated by the Board of Directors will be carried out under the direction of the Affirmative Action Coordinator.
DEFINITIONS
The terms “underutilization” and “under-representation” appearing in this Affirmative Action Plan are used in the context that these terms are used in regulations promulgated by the Office of Federal Contract Compliance Programs. These terms have no independent legal or factual significance whatsoever.
Many statistical comparisons herein involve the use of geographic areas and various other sources of statistics. The use of such geographic areas and statistics is intended only for the purpose of implementing this Affirmative Action Plan and will be used in total good faith.
UNDERUTILIZATION ANALYSIS
The analysis in this Affirmative Action Plan addresses differences in the utilization rate of women and ethnic minorities in the Zillah School District as compared with their stastical availability in a reasonable recruitment area. Where there is a valid statistical difference that indicates the underutilization of women or ethnic minorities, this difference is noted. In analyzing the Zillah School District’s work force for evidence of possible underutilization, the general approach used is to compare the “protected class” percentage of the Zillah School District employees in various job classifications to the percentage of this class in the available work force. In establishing by comparison figures representing the available work force, data was taken from information provided by the Census Bureau. A summary of the census bureau data used is presented below as Table 1.
SALARY RANGES
Following is a list of salary ranges for all job classifications
Position Salary Range
Executive Directors $100,912 – 119,428 annually
Administrators $ 64,806 – 104,307 annually
Teachers $ 32,746 – 61,720 annually
Para-educators $ 11.85 – 13.69 hourly
Administrative Support – Exempt $ 16.82 – 37.83 hourly
Secretaries $ 11.92 – 16.45 hourly
Bus Driver $ 13.91 – 17.03 hourly
Food Service $ 12.03 – 14.46 hourly
Custodial $ 13.64 – 17.13 hourly
Maintenance $ 15.94 – 18.84 hourly
Athletics and Extra-Curricular $ 655 – 6083 per assignment
NUMERICAL REVIEW ANALYSIS
Marital Status, Age The Zillah School District’s commitment in these areas is based on the reaffirmation of its practice of avoiding discrimination in all aspects of employment in regard to members of these groups. The Zillah School District has reviewed and revised its employment application forms to reduce the possibility of discrimination in these and other areas. The staff responsible for hiring in the Zillah School District will continue to ensure the absence of discrimination based on age or marital status. Data indicates that 55.2% of the Zillah School District’s certificated staff members and 87.1% of the classified staff members are age 40 or over.
Persons with Disabilities In compliance with Section 504 of the Vocational Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990, the Zillah School District is committed to the avoidance of discrimination in hiring and promotion of persons with disabling conditions. The Zillah School District is also committed to making reasonable accommodations to allow disabled employees the opportunity to be successful. The action of the Zillah School District with respect to this group is to reaffirm its strong commitment to avoid illegal discrimination in all aspects of employment in regard to disabled individuals. As one demonstration of this commitment, the Zillah School District includes on vacancy announcements and application inserts a statement encouraging persons with disabilities to apply.
Vietnam-Era/More Recent Military Action Veterans The Zillah School District’s commitment for these groups involves the reaffirmation of its commitment to avoid discrimination in all aspects of employment with regard to disabled and Vietnam-era veterans. Although it seems clear that the number of individuals from these categories seeking entry-level positions is decreasing over time, the Zillah School District maintains its commitment to avoid discrimination in employment practices related to this group. Staff responsible for hiring and promotion will be given information designed to sensitize them to the potential for discrimination in this area. This information will be reviewed in meetings with the management team as we begin implementation of the newly adopted Affirmative Action Plan. In addition, the Zillah School District will include a statement on this job vacancy announcement encouraging disabled and Vietnam-era veterans to apply.
Utilization Analysis for Ethnic and Gender Composition The term “underutilization” is taken from the regulations promulgated by the Office of Federal Contract Compliance Programs. This term has no independent legal or factual significance whatsoever. The term “underutilization” as used in this policy means having fewer members of an affected group in a particular job category than reasonably would be expected upon their availability. The statistical comparisons in this section involve the use of workforce statistics for geographic areas relevant to the Yakima County area derived from public census reports. The use of such geographic areas and statistics is intended only for the purpose of implementing this Plan and facilitating identification of areas of potential underutilization. Most of these reports are available on the Office of Superintendent of Public Instruction’s website.
When the term goal is used, it is expressly intended that it should not be used to discriminate against any applicant or employee because of race, color, creed, religion, age, sex, ethnicity, national origin, veteran status, marital status, or the presence of a sensory, mental or physical disability.
Many comparisons herein involve various sources of statistics. The use of such statistics is intended only for the purpose of implementing this Affirmative Action Program and will be used in good faith.
This analysis is based on a comparison of the composition of the district’s workforce with the availability of ethnic minorities and women in various job classifications based on census information as summarized in Table 1. To identify instances of underutilization, the 4/5 or 80% rule was applied. Where underutilization was identified, it is noted on Table 3.
Further analysis applying the “4/5 or 80% rule” was conducted to identify underutilization which is statistically significant. Where underutilization is identified, the long-range goal is to eliminate such underutilization. When this is accomplished, the goal will no longer remain. An annual utilization review for the various job categories will be the basis of measuring progress toward this goal. In addition, where underutilization is identified, an immediate, short-range goal is to hire qualified underutilized individuals for the affected job category in a proportion which is at least equal to the proportion of underutilized individuals available in the job market.
The steps used to conduct the 4/5 or 80% rule are: 1. Calculate the percentage of minorities and women available in the labor market. 2. Calculate the percentage of minority and women employees. 3. Determine whether the percentage of employees is less than, greater than, or equal to 4/5 of the available labor market. 4. If the percentage of employees is less than 4/5 of the available labor market, underutilization exits. If the percentage of employees is greater than or equal to 4/5 of the available labor market, underutilization does not exist. A detailed description of this process is included as Appendix D.
Table 4 below summarized the composition of district employees with respect to ethnic categories and gender. This summary includes only regular full and part-time employees – it does not include substitute and temporary employees.
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