How does a sponsor determine the availability of qualified individuals within its recruitment area?

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.  

1. Workforce analysis:  Identifies the racial, sex, and ethnic composition of the sponsor’s apprentice workforce
2. 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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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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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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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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