3J Interviews

Conducting interviews is the fourth activity in a construction on-site review. Interviews typically take place during the CO’s worksite inspection of the contractor’s federal and nonfederal projects. COs should prepare interview outlines and/or questions in advance of the on-site, referencing FCCM 2F, Interviews. COs should conduct sufficient interviews of employees and supervisors to resolve any outstanding issues or questions. This includes interviewing these key groups:

• Supervisors, to determine if they are aware of and adhere to the affirmative action specifications. Supervisory personnel are often the individuals to whom applicants speak concerning employment opportunities, and they are likely to make job and overtime assignments;
• Current employees (nonminority males, as well as minorities and women);
• Union officials, if applicable;
• Applicants (nonminority males, as well as minorities and women); and
• Former employees (nonminority males, minorities and women) to determine how the contractor and co-workers treated them on the job.

If the contractor has only a few women or minorities in its construction workforce, COs will make every effort to interview each one. If all the women and minority employees cannot be interviewed, COs should select a representative sampling from each trade for interview. These interviews should probe for any evidence of discrimination, including harassment, and other indicators of noncompliance.

COs will refer any complaints received from employees during these interviews related to the Davis-Bacon Act wage rates to the DOL’s WHD.