AAP Plan - Grouping Employees
Kymm
140 Posts
I am currently doing an AAP plan for our AZ facility. We also have a smaller facility in southern California (only about 16 people). I handle the human resources function for their facility as well (and I am located in the AZ facility.) I am now reading that because of that, I can actually put those 16 people on our Arizona AAP plan - does that sound right?
Comments
I believe it depends on whether you allow free transfer between the facilities, that is, if you post an open job in one facility an employee from the other can apply for it. If this is the case then you can group them all together. If it isn't the case I wouldn't think you would even need an AAP for an indepedent facility of 16 people - the trigger point is 50 employees.
I had two facilities, 8 miles apart, with 200 in one and 22 in the other. Since the 200-employee plant was union, no transferring was done between plants. Due to this, the OFCCP said I did not need an AAP for the 22 employee plant and did not need to include these folks in my larger AAP. Of course, this might be EEOC region-based. Why not call your local OFCCP office and ask?
Sunny