Do sponsors need to send their Affirmative Action Plan to the Registration Agency every time they update it?

The written Affirmative Action Plan must include the following components:

• Workforce analyses for race, sex, and ethnicity (comparing the workforce and availability analyses)        
• Utilization goals for race, sex, and ethnicity (if necessary) 
• Utilization goals for individuals with disabilities
• Targeted outreach, recruitment, and retention activities (if necessary) 
• Review of personnel processes
• Invitations to self-identify as an individual with a disability

Each of these components requires a sponsor to examine different elements of its apprentice workforce, document its review, and determine whether any element of its program is adversely impacting individuals within certain groups.  A guide preparing sponsors to develop their plans is available on the Create Your Plan Equal Employment Opportunity webpage.

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The apprenticeship Equal Employment Opportunity regulations require certain Registered Apprenticeship Program sponsors to develop Affirmative Action Programs.  An Affirmative Action Program assists sponsors in detecting, diagnosing, and correcting any barriers to equal opportunity that may exist in its apprenticeship program.  Further, an Affirmative Action Program is designed to ensure equal opportunity and prevent discrimination in apprenticeship programs.  A sponsor’s written Affirmative Action Plan states the specific steps sponsors will take to ensure all qualified applicants and apprentices receive equal opportunity to be selected for – and succeed in – Registered Apprenticeship Programs.

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Sponsors required to develop Affirmative Action Programs must conduct an annual review of their personnel practices to help ensure the program is free from unlawful discrimination.  This must be a careful, thorough, and systematic review of all aspects of the program, including, but not limited to:

• Qualifications of apprentices
• Application and selection procedures
• Wages
• Outreach and recruitment activities
• Advancement opportunities
• Promotions
• Work assignments
• Job performance
• Rotations among all work processes of the occupation
• Disciplinary actions
• Handling of requests for reasonable accommodations, and
• The program’s accessibility to individuals with disabilities 

The written Affirmative Action Plan must include a description of the review the sponsor undertook, and any modifications made to its practices as a result of the review.

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The deadline for sponsors registered with the national Office of Apprenticeship to put an initial Affirmative Action Program in place is two years after a program’s registration date, or two years from the date the program registers its fifth apprentice – whichever is later.  The Affirmative Action Program deadline for sponsors registered with State Apprenticeship Agencies depends on their state Equal Employment Opportunity plan.

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