Sponsors should make good faith efforts to seek alternative or additional sources that are more effective at referring diverse qualified applicants. The Office of Apprenticeship has provided information and online resources to sponsors regarding recruitment sources. During compliance reviews, sponsors would only be expected to describe their good faith efforts to recruit diverse apprentices.
If the sources that a sponsor is using to meet its outreach and recruitment obligations are not generating referrals from the various demographic groups in the sponsor’s recruitment area, what should the sponsor do?
Equal Employment Opportunity
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The universal outreach and recruitment provision requires sponsors to send advance notice of all program openings to the recruitment sources on its outreach and recruitment list. A sponsor that has continuous open enrollment should send its position postings to its recruitment sources regularly, as well as whenever there is any change to the apprentice position posting or description. Generally speaking, a sponsor will satisfy this requirement by sending out the posting on a quarterly basis (and any time the posting changes). When evaluating a sponsor’s compliance with this requirement, the Office of Apprenticeship will take into account circumstances in which quarterly postings may not be cost-effective (e.g., for a very small program where there are hardly any openings) or might not be sufficient (e.g., for a program that has a very large number of openings every month).
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If the requirement to have a driver’s license impacts any protected group adversely, such a requirement should be validated to ensure it is job-related and consistent with business necessity. For example, an apprenticeship program that involves traveling to different sites may require apprentices to use personal or company transportation to these sites. If driving is not an essential function of the job, the requirement to have a driver’s license may not be consistent with business necessity and may adversely affect certain individuals with disabilities or other protected groups.
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Under the Equal Employment Opportunity regulations for Registered Apprenticeship Programs, sponsors must develop and update annually a list of current recruitment sources that will generate referrals from all demographic groups within the relevant recruitment area. Examples of relevant recruitment sources include the public workforce system’s American Job Centers and local workforce development boards; community-based organizations; community colleges; vocational, career, and technical schools; pre-apprenticeship programs; and Federally-funded youth job training programs such as YouthBuild and Job Corps or their successors. The Office of Apprenticeship (OA) has developed a Universal Outreach Tool to assist sponsors in expanding their outreach and recruitment efforts. The tool can be accessed from the Universal Outreach Tool link on the Apprenticeship Equal Employment Opportunity Recruit and Hire webpage.
OA encourages program sponsors to post their apprenticeship openings with their respective state job banks and local American Job Centers. For more information about posting opportunities with state job banks, please visit the Career One Stop site.
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No. Sponsors are not permitted to engage in preferential hiring based on race, sex, or any other protected category. Further, nothing in the Equal Employment Opportunity regulations requires sponsors to select unqualified applicants or a less qualified person in preference to a more qualified one. Indeed, doing so on the basis of a protected characteristic like race or sex would be unlawful under the regulations.
Sponsors are required to engage in outreach and recruitment activities designed to reach all demographic groups within the relevant recruitment area and need to ensure that their programs offer equal employment opportunities to all apprentices and applicants. Further, sponsors required to maintain Affirmative Action Plans may need to set race, sex, ethnicity, or disability utilization goals – if they find that their programs underutilize any of these particular groups. However, these goals are not quotas; they do not provide a sponsor with justification to extend a preference to any individual on the basis of a protected characteristic, nor do they permit sponsors to create set-asides for specific underrepresented groups. For example, the regulations make it clear that sponsors should not establish separate ranking lists based on protected characteristics.
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