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Several months ago Deputy Assistant Secretary Charles E. James of the Office of Federal Contract Compliance Programs (“OFCCP”) signed the Functional Affirmative Action Plan Directive outlining provisions for contractors to request approval to prepare functional, rather than establishment, based plans. Contractors have had varied success in getting such requests approved. It is, however, worth making the request if an employer’s business is structured in such a manner that preparing plans by physical location has little meaning. For example, if reporting relationships are based on a business line consisting of geographically dispersed employees, rather than on the location at which the employee physically reports to work, a functional plan may be appropriate.