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?
Equal Employment Opportunity
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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 regulations do not require utilization analyses or goal calculations for older workers or veterans.
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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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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.
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