Equal opportunity employment litigation has caused employers to accord women greater hiring, training, and promotional opportunities. The increasing number of women in their childbearing years who have entered the labor market, coupled with the persistent sex discrimi nation in the labor market, however, have resulted in strained relations between employers and employees. Employment policies that strive to protect female employees and their offspring from hazardous conditions in the work place provide an example of one such trouble spot. These employment policies are known as fetal protection policies. In the implementation of these policies, there often appears to be a direct clash between the Occupational Safety and Health Act (OSH Act)1 and Title VII of the Civil Rights Act of 1964.2 Employers who exclude women from certain jobs which they deem hazardous in an effort to comply with the OSH Act must often deal with angry female employees who argue that the employers are violating Title VII's prohibition against sex and pregnancy discrimination. It has been estimated that as many as 20 million jobs in this country may involve exposure to substances which involve a risk of reproductive hazards to employees.3 Therefore, this clash between the OSH Act and Title VII represents a major legal and moral issue of public policy. Title VII prohibits discrimination in employment on the basis of sex. Specifically, 42 USCS Section 2000e-2(a) provides as follows: