Generally, it should not. If journeyworkers are eligible for enrollment in the apprenticeship program, those workers should be included within the sponsor’s availability analysis. However, currently employed journeyworkers should not be included in the sponsor’s workforce analysis.
Should a sponsor include journeyworkers who mentor apprentices in its analyses?
Equal Employment Opportunity
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Yes. The Registration Agency will provide significant technical assistance during compliance reviews to help sponsors conduct their availability and utilization analyses. An automated tool has been developed for staff to use in helping sponsors conduct the analyses. The Demographic Analysis Tool simplifies the process, by using the most recent Census data on all workers in the civilian labor force (persons working and those looking for work) to perform the availability analyses. The tool also allows staff and sponsors to easily identify where the program is underutilizing women or ethnic/racial minorities.
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Conducting utilization analyses helps sponsors identify deficiencies and determine whether they need to set utilization goals. The analyses provide sponsors with a method for assessing whether possible barriers to apprenticeship exist for particular groups of individuals by determining whether the race, sex, ethnicity, and disability status of apprentices in a sponsor’s apprenticeship program is reflective of qualified individuals in the sponsor’s relevant recruitment area. The results of the analyses will help sponsors decide whether and how to develop and engage in targeted outreach and recruitment activities to help meet Equal Employment Opportunity requirements.
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The Equal Employment Opportunity regulations specify conducting utilization analyses by major occupation group to provide a larger data set for comparing to the availability data and deciding if goals need to be established. For many programs, a utilization analysis at the occupational title level would not be very helpful because there are not many apprentices within each occupation.
The regulations require use of the more granular occupational title data when sponsors perform internal analyses of their workforces, such as during their annual reviews of personnel practices. Having data broken down by occupational title allows sponsors to review their apprentice workforces at a deeper level that could be overlooked when titles are combined in the utilization analysis.
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The regulations do not require utilization analyses or goal calculations for older workers or veterans.
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