UA & MCAA Comment on Proposed DOL National Apprenticeship System Enhancements

March 19, 2024

The UA and MCAA recently submitted comments on the U.S. Department of Labor’s (DOL) proposed enhancements to the national apprenticeship system. The UA and MCAA strongly support provisions in the rule which will bolster successful registered apprenticeship programs and the safety and welfare of apprentices.

The UA and MCAA strongly support provisions in the rule which will bolster successful registered apprenticeship programs and the safety and welfare of apprentices:

  • Proposed minimum requirements of 2,000 hours of on-the-job training (OJT) and 144 hours of related instruction for every 2,000 hours of OJT.
  • Proposed changes that give the DOL the sole authority to determine which occupations are suitable for registered apprenticeship.
  • Stronger reporting and enforcement provisions for registered apprenticeship programs.

At the same time, the organizations oppose certain provisions of the proposed rule, stating that:

  • Exemptions from the requirements of 29 CFR Part 29 should not be allowed
  • National occupational standards are unnecessary and would be harmful to registered apprenticeship programs in the plumbing and mechanical trades
  • National program standards should continue to be required to comply with local requirements
  • The UA and MCAA oppose the creation of CTE (career and technical education) apprenticeships
  • The proposed rule’s prohibition on non-compete agreements is overly broad and will negatively impact valuable scholarship loan agreements
  • The definition of pre-apprenticeship program should clarify that the hands-on training component is voluntary
  • The definition of journeyworker should not be changed

MCAA Government Affairs Committee Chair Jim Gaffney noted that, “Ensuring and supporting top-tier training in the construction industry is more important now than ever, given the massive investments being made to the nation’s infrastructure and manufacturing capabilities.”

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