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?
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The availability analysis looks at the racial, sex, and ethnic breakdown of qualified individuals available for apprenticeship in the sponsor’s recruitment area. Individuals are considered qualified if they meet the basic requirements for enrollment in the apprenticeship program. Registration Agencies work closely with each sponsor during regular compliance reviews to develop and conduct an availability 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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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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