ARLINGTON, VA – On June 25, The U.S. Department of Labor (DOL) issued a notice of proposed rulemaking (NPRM) designed to encourage the creation of apprentice training programs across a wide variety of industry sectors. These programs are known as Industry-Recognized Apprenticeship Programs, or IRAPs.
TAUC represents more than 2,000 union contractor firms that annually employ tens of thousands of craftworkers from the 14 international building trades unions. While we commend DOL and other industries for seeking to create apprenticeship programs, our first and highest priority is to protect the gold-standard, time-tested system already in place in "our own backyard" – namely, the current privately funded registered apprenticeship model for the union construction and maintenance industry.
Each year, the building trades unions and their contractor partners collectively spend $1.6 billion to fund more than 1,600 registered training facilities across the country. This incredible investment signals a steadfast and ongoing commitment to the highest levels of quality, safety and craftsmanship for our clients. Therefore, we must examine carefully any government proposal, no matter how well-intentioned, that could potentially weaken the effectiveness of our privately funded apprenticeship system and inadvertently lower training and safety standards across the entire industry.
For instance, its proposed rulemaking, DOL states that it would not, "at least initially," accept applications to recognize IRAPs in the construction industry. Does this mean that DOL will allow construction IRAPs after a year? Two years? Three? Obviously, this vague caveat concerns us, and we will seek to have the Department clarify its intentions. Our position is that no construction IRAPs should be approved by DOL, period.
TAUC will also urge the Department to clarify that it will not approve any IRAPs relating to construction maintenance as well as construction, since these activities are so closely linked, especially on industrial construction and maintenance projects.
Between now and the comment deadline of August 26, 2019, TAUC and its member contractors will work hard to submit detailed and well-informed comments on the NPRM. Again, we commend the DOL for seeking to expand and improve apprenticeship training programs in the United States. We are dedicated to working hand-in-hand with the Department to achieve that noteworthy goal, so long as our own singular success – the privately funded registered apprenticeship model – is allowed to continue to grow and thrive.