The workforce analysis should use the sponsor’s apprentice data, regardless of whether or not the sponsor is also the employer.
When the sponsor is an organization that places apprentices with participating employers, which data should be used in the analyses – the sponsor’s apprentice workforce data or the participating employers’ data?
Equal Employment Opportunity
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The EEO regulations for Registered Apprenticeship Programs require sponsors that must maintain an Affirmative Action Program to conduct two types of analyses and compare those analyses to each other.
- Workforce analysis: Identifies the racial, sex, and ethnic composition of the sponsor’s apprentice workforce
- Availability analysis: Determines the racial, sex, and ethnic representation of qualified individuals available in the relevant recruitment area
The utilization analysis is the comparison of the workforce analysis to the availability analysis. The results of the utilization analysis tell the sponsor if its utilization of women, Hispanics or Latinos, or a particular racial minority group is significantly less than would be reasonably expected given the availability of such individuals for apprenticeship. The specific steps for conducting the analyses are included in the Developing Affirmative Action Programs and Plans guide.
Workforce analyses must also be conducted to identify the number of apprentices in the program with disabilities. Unlike race, sex, and ethnicity, the proportion of apprentices with disabilities in the program is compared to a national aspirational goal of 7%.
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If the sponsor recruits separately for discrete locations, each training location will conduct its own utilization analysis and, with the assistance of Registration Agency staff, will identify the appropriate recruitment area for those locations. If the program recruits nationally for a centralized training location, the program will conduct the analysis using national-level Census data. Registration Agency staff will be trained to assist sponsors in conducting analyses using Census data, as well as the Demographic Analysis Tool.
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The regulations do not require utilization analyses or goal calculations for older workers or veterans.
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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.
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