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.
How can a sponsor that recruits nationally use the Demographic Analysis Tool to capture relevant recruitment data?
Equal Employment Opportunity
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The regulations do not require utilization analyses or goal calculations for older workers or veterans.
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Yes. The Registration Agency will provide significant technical assistance during compliance reviews to help sponsors conduct their availability and utilization analyses. An automated tool has been developed for staff to use in helping sponsors conduct the analyses. The Demographic Analysis Tool simplifies the process, by using the most recent Census data on all workers in the civilian labor force (persons working and those looking for work) to perform the availability analyses. The tool also allows staff and sponsors to easily identify where the program is underutilizing women or ethnic/racial minorities.
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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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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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