The category or target group "women" can also be misleading. For example, on March 9,1988, the Treasury Board announced that women promoted to the management category in the Federal Public Service had exceeded their desired goal of 475; the number of women in senior management positions had increased from 217 in 1983 to 509 in 1988. However, it is highly likely that the majority of these women are white and able-bodied. Immigrant women's groups are lobbying also for the recognition of educational and professional experience gained in non-Canadian backgrounds. Employment Equity must therefore take into account Education Equity and specifically examine the problems of accreditation and of foreign-acquired degrees and professions.

Public disclosure has been touted as a "unique aspect" of the Employment Equity Act. In January 1986, then Minister of Employment and Immigration, Flora MacDonald, said "these companies will have to answer to the people of Canada if they fail to achieve employment equity." According to the government, then, public disclosure allows the general public to monitor and evaluate the effectiveness of the Act, but, although available in public libraries, the reports are not as accessible as they are claimed to be. For those wishing to obtain a set the cost is $2,000.

According to John Aferton at the Employment Equity Branch, "public scrutiny is the cornerstone of this Act." Commenting on essays that are critical of the legislation, Aferton states, "we don't have a lot of experience with this. As a starting point, the kind of information we collect (i.e. employers' reports) is vital, is crucial, and sometimes this point is missed." By making information about employment practices of federally regulated businesses available to the public, the government thinks humiliation and shame are sufficient enforcement tools. On the contrary, some companies might find it cheaper to pay the penalty for failure to report rather than make a report or implement a program. Public outrage cannot confront and tackle the widespread discrimination that exists and leaving it up to the Human Rights Commission to initiate an investigation is simply not enough.

There is no mechanism to guard against poorly devised plans with no meaningful goals or timetables. The process of consultation between employers and employees of designated groups is vague; meaningful consultation between the union or employee representatives is not possible if the employee representatives do not have a right to see the plan. Ultimately, the burden of trying to do something falls, once again, on the backs of the disadvantaged.

A Globe and Mail article (Wednesday, April 12, 1989), entitled "HIRE MORE WOMEN AND MINORITIES NOW, FIRMS WARNED," opens with the following: "Companies should begin increasing the number of women and minorities they employ to avoid having 'cumbersome' employment equity laws thrust upon them, an authority on the issue says." If companies are going to be encouraged to hire "women and minorities" on the basis of avoiding "cumbersome laws," then the intent of the legislation has failed. In fact, such actions will be more damaging because those hired for this reason will likely find themselves working where no affirmative action or anti-racist policies exist.

The four target groups have been calling for drastic alteration since the Bill was first introduced. The demands include: mandatory affirmative action programs, a central enforcement agency, goals and timetables, community and target group input into the planning, data collection, analysis and implementation of the Act. As it stands now, the legislation does nothing more than let government claim it has done something for disadvantaged workers when, in fact, little has changed as a result of its passage.

Changes are imperative for the Federal Contractors Program as well. The program should, at minimum, specify numerical goals and timetables to be achieved by the contractors; require public reporting of data; levy penalties for non-compliance and broaden coverage from 100 employees and a $200,00 contract to 20 employees and a contract of $50,000 or more.

An increasing number of companies are producing glossy, finely worded pamphlets which articulate a commitment to employment equity. However, as long as the federal employment equity policy lacks specific goals and timetables, systematic monitoring mechanisms and effective sanctions for non-compliance, Canadians would be ill-advised to expect that policies will be translated into good practices.