Our Apprenticeship Program is under attack
Comments are due by midnight on August 26, 2019.
A proposed new U.S. Dept. of Labor regulation will reshape apprenticeship programs across a wide range of industries. The DOL is proposing Industry Recognized Apprenticeship Programs (IRAP) as an attempt to expand apprenticeship programs.
As of now, IRAPs are only being proposed for industries that either do not have a formal apprenticeship program or where such an apprenticeship program has not been successful.
The proposal does not include language that permanently exempts the construction industry from IRAPs and therefore our long-standing, highly successful union apprenticeship programs could find themselves threatened by unregulated IRAPs permeating the industry.
What are IRAPs ?
IRAPs are apprenticeship programs that are not registered with either a state or federal department of labor. They are approved by private industry entities with substandard requirements compared to registered apprenticeships.
Employers can pay apprentices minimum wage or in some cases stipends that could be below minimum wage.
Employers are not required to give wage increases over the course of the apprenticeship.
There is no minimum requirement for the length of time or the amount of educational or instructional training that an apprenticeship receives.
There are no safety training requirements for apprentices.
There are no qualification requirements for apprenticeship instructors.
What are the risks ?
IRAPs are a threat to the NEIEP apprenticeship and all construction trade apprenticeship programs. Allowing IRAPs in construction will devastate the recognized apprenticeship program and start a race to the bottom for lower wages, benefits and training. Apprentices, Mechanics and Retirees will all feel the effects as IUEC employers are unable to compete with companies using the easily exploitable pool of construction workers created by these IRAPs.
The key construction provision in the proposed rule, would exempt the industry from taking part in IRAPs, “at least initially,” DOL says. [View text of proposed regulation here.]
To protect our Apprenticeship programs, we need the DOL to permanently exempt the construction industry from IRAPs. It’s essential that we submit comments supporting real Registered Apprenticeship Programs in construction to the DOL.
Comments are due by midnight on August 26, 2019. Please take a few minutes to support registered apprenticeship programs in construction and the future of construction trade workers.
This link will allow any Elevator Constructor Mechanic, Apprentice or Retiree to complete an online individualized comment letter and directly submit it to the DOL.
This link will allow any voting American to complete an online individualized comment letter and directly submit it to the DOL.
This link will allow individuals to write original letters stressing the importance of permanently exempting Construction Registered Apprenticeship from IRAPs.