The deadline for sponsors registered with the national Office of Apprenticeship to put an initial Affirmative Action Program in place is two years after a program’s registration date, or two years from the date the program registers its fifth apprentice – whichever is later. The Affirmative Action Program deadline for sponsors registered with State Apprenticeship Agencies depends on their state Equal Employment Opportunity plan.
When do Affirmative Action Programs need to be in place?
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The apprenticeship Equal Employment Opportunity regulations require certain Registered Apprenticeship Program sponsors to develop Affirmative Action Programs. An Affirmative Action Program assists sponsors in detecting, diagnosing, and correcting any barriers to equal opportunity that may exist in its apprenticeship program. Further, an Affirmative Action Program is designed to ensure equal opportunity and prevent discrimination in apprenticeship programs. A sponsor’s written Affirmative Action Plan states the specific steps sponsors will take to ensure all qualified applicants and apprentices receive equal opportunity to be selected for – and succeed in – Registered Apprenticeship Programs.
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The written Affirmative Action Plan must include the following components:
- Workforce analyses for race, sex, and ethnicity (comparing the workforce and availability analyses)
- Utilization goals for race, sex, and ethnicity (if necessary)
- Utilization goals for individuals with disabilities
- Targeted outreach, recruitment, and retention activities (if necessary)
- Review of personnel processes
- Invitations to self-identify as an individual with a disability
Each of these components requires a sponsor to examine different elements of its apprentice workforce, document its review, and determine whether any element of its program is adversely impacting individuals within certain groups. A guide preparing sponsors to develop their plans is available on the Create Your Plan Equal Employment Opportunity webpage.
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Yes. The exemption is based on the total number of apprentices per sponsor – not per employer. Thus, if the number of apprentices in the sponsor’s program is five or more, the sponsor is required to maintain an Affirmative Action Program. Regardless of the number of employers or the distribution of apprentices across them, if the total number of apprentices is five or more, the sponsor is required to have an Affirmative Action Program.
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The Affirmative Action Program is the general activities that sponsors engage in to support equal opportunity in recruitment and hiring of all qualified individuals.
The Affirmative Action Plan is the written documentation of these activities. Sponsors do not need to submit the Plan to the Registration Agency but must make it available upon request, including during compliance reviews.
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