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Washington, D.C. -- April 06, 2004 -- In March, the Equal Employment Opportunity Commission (EEOC), with the Departments of Labor and Justice and the Office of Personnel Management (OPM), published in the Federal Register a coordinated document to clarify recordkeeping provisions concerning who is an "applicant" in the context of the Internet and related email technologies.

As most employers have found out first hand, the use of the Internet for recruitment and receiving job applications has grown exponentially over the last decade. These technological advances have left employers unsure at what point prospective employees become actual “applicants.”

The proposed guidelines state that those individuals who apply for jobs electronically must be considered applicants for EEOC recordkeeping purposes. According to the proposal, this means that the individual has followed the employer’s standard procedures, has indicated interest in a specific position and the employer has acted to fill that particular position.

NAM wants to hear from manufacturers who have dealt with this issue so that they can file substantive comments on this proposal. After reviewing the document at www.nam.org/eeocdoc, please share your comments or thoughts about the proposed guidelines with Chris Tampio.

There is a sixty-day comment period, and comments are due by May 28, 2004. Please send your comments to the NAM by May 17 so that they may compile a complete record. If you have any questions or cannot view the proposal, please contact Chris Tampio.

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