Document 33D: Cathy Beckmann, Women in the Trades, to Equal Employment Opportunity Commission, 6 May 1980 (Files of the Equal Employment Opportunity Commission, Washington D.C.).

WOMEN IN THE TRADES

198 FORSYTHE ST., NEW YORK, NY 10002    260-4560

6 May 1980
Tuesday

Executive Secretariat
Equal Employment Opportunity Commission
2401 E Street, NW Room 4096
Washington, DC 20506

RE: SEXUAL HARASSMENT GUIDELINES
issued 11 April 1980

   WOMEN IN THE TRADES (W.I.T.T.) wishes to make the following comments on the above issued guidelines, as appearing in the Federal Register of April 11, 1980, pages 25024 and 25025.

1. regarding section 1604.11 (a) Due to past experiences, WITT feels that every effort should be made to include that of a psychological nature should also be included.

   regarding section 1604.11 (a) (3). We feel that this section should be more firmly written to define what would constitute an "offensive" environment. While further in the proposed regulations, it is stated that"…the commission will look at the record as a whole.", we feel that this alone is not sufficient to protect the worker's perceptions, which in some cases, are the only way of determining harassment.

2. Women in the Trades questions whether "age" is also included in EEOC guidelines, and if it is, we feel it should also be protected under these guidelines, as age discrimination has often led to forms of sexual harassment.

3. Sections 1604.11 (c) and (d). From reading these proposals, we are unclear as to whether the employer would be responsible for whatever damages are involved, or whether the supervisors and others will also assume individual responsibility.

4. While we understand the limitations legally, we wonder why the emphasis seems to be only on supervisors, etc. - does the EEOC forsee when, or if, the issue of sexual harassment between coworkers will also be covered?

Awaiting the final regulations, we are

Very truly yours,
In Sisterhood and Solidarity

for WOMEN IN THE TRADES