Protect Our Apprenticeship and Training Programs

Our BAC members are the most highly skilled craftworkers in the world. We are the “Best Hands in the Business,” because our members go through a rigorous education and training system – our Apprenticeship and Training programs. We are very proud of these programs because they provide state-of-the-art comprehensive skills and safety training, with a combination of classroom and work-based instruction. Our Apprenticeship system is collectively bargained and jointly managed by the Union and management. It is the gold standard for education and training. That is why we have been concerned about efforts to expand the Apprenticeship model in a way that could lower standards and lack accountability.

Our programs are Registered Apprenticeship programs under the National Apprenticeship Act. They are subject to the stringent standards and oversight of the U.S. Department of Labor’s Office of Apprenticeship and Training or a recognized State agency.

We have been watching closely as the Trump Administration has moved forward in developing Industry Recognized Apprenticeship Programs (IRAPs). The IRAP proposal is designed to expand the Apprenticeship model to new and emerging industries, and industries that have not been successful using the Registered Apprenticeship system.

In the rule, the Department of Labor proposed excluding the construction industry and military from its Industry-Recognized Apprenticeship Programs (IRAPs), at least for the time being. After a 60-day public comment period, a final rule will be announced that could reverse the initial decision to exclude the construction industry.

On June 25th, the U.S. Department of Labor posted a proposed rule on IRAPs in the federal register. The public has been given 60 days to submit comments on the proposal. Those comments will be considered before the rule goes final.

The Building Trades Unions have had more than 100 years of experience in running Apprenticeship programs for the various trades in construction. We always work together with our employers to ensure that our training programs meet the needs of the industry and provide our members with a pathway to a career with fair wages, good benefits and a secure retirement. Any new rule must protect the integrity and high standards of the existing construction industry Registered Apprenticeship system.

As indicated above, the Department of Labor is accepting comments on the proposed rule. Comments are due on August 26th. We urge all BAC members to submit comments on the proposal. The primary issue to comment on is the exclusion of the construction industry from the IRAP system. It is critically important that this exclusion is included in the final rule. You might want to include your own personal story on how important the Registered Apprenticeship system has been to you.

IRAP issues:

• The Construction Industry must be exempted; and “construction” must be broadly defined.
• IRAPs are a poor, potentially dangerous imitation of our collaborative union-contractor apprenticeships and are designed to cut corners, weaken standards, lower quality and reduce wages so that unscrupulous contractors get rich and participants don’t. We cannot allow IRAPs to undercut our proven model of training and safety.
• IRAPs do not require union or employee representation. An entirely employer-controlled system may completely ignore the worker’s perspective.
• IRAPs do not require that apprentices to be paid well or receive periodic increases, the only requirement is that they receive the minimum wage.

Please submit your comments about this proposal on page 2 by mail to Adele Gagliardi, Administrator, Office of Policy Development and Research, U.S. Department of Labor, 200 Constitution Avenue, NW, Room N-5641, Washington, D.C. 20210. You can also submit your comments via email: OIRA_submission@omb.eop.gov or on our website at: saveBACapprenticeships.org.