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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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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The regulations do not require utilization analyses or goal calculations for older workers or veterans.
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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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