OFCCP recently announced a settlement with Becton Dickinson for $100,000 in back pay and interest to 104 African American female employees. The female employees in manufacturing and operations positions were allegedly paid less than males and other non-African American females. This settlement covered two facilities in Sparks and Hunt Valley, Maryland.
The settlement is intriguing as it involves the intersection of two protected classes, African American and female. OFCCP has indicated an interest regarding the intersection of race and gender, but to date has not had many settlements in this area. In this era, Berkshire recommends a proactive pay equity and gap analysis for all contractors, and particularly for those on the OFCCP list to be audited in the next 12 to 18 months.