OA ALL STAFF TRAINING September 26, 2007 PROGRAM REGISTRATION

1. OA ALL STAFF TRAININGSeptember 26, 2007PROGRAM REGISTRATION BY JOHN DELGADO FRANCHELLA KENDALL

2. PURPOSE • Program Registration – a review of the process to verify information on registered apprenticeship program sponsors, i.e., physical address, background on employer, affiliation with Labor, associations or other companies, overview of Program Sponsor Electronic Registration.

3. Congressional Inquiry Dear Regional Director: I recently received inquiries and questions from some of my constituents concerning what appears to be a new construction company XYZ company…….. I am told that XYZ was awarded a contract by CBA to install……………….. Further, I am told by those who recently visited the job site …that around 7 workers on the job stated that their pay ranged between $14.00 and $27.00 per hour and XYZ calls them “apprentices” even though they indicated they had no previous training. In addition, I am told that XYZ was approved by the U.S. Department of Labor (DOL) as an Apprenticeship Training Center in the past month or so. As you are aware, the Apprenticeship Program is established by Federal Regulations 29 CFR 29 and 29 CFR 30, and there are stringent requirements that must be met to achieve this status.

4. Congressional Inquiry (con’t) Please consider this as my request for your office to immediately investigate the following: Did DOL verify that employees of XYZ Company do in fact have at least 7 years of experience in a craft to be considered a “journey worker?” If so, how did DOL go about the verification process? Did DOL independently do the verification or simply accept documents form XYZ? Does XYZ have a job training outline and a curriculum outline as required for the entire length of the apprentice program? If so, can DOL document these outlines? What specific determination did DOL issue to certify XYZ as an Apprenticeship Training Center? I understand that Mr. CBA is the chief financial officer of XYZ. Since XYZ was awarded this contract by CBA Construction Company, I would be interested if Mr. CBA is associated with CBA Construction Company from another state?

5. CONGRESSIONAL INQUIRY How would you answer the following? • Is your information in RAIS/RAPIDS complete? • Would you have this information in your file or would you have to scramble for it? • How long would it take for you to send the information requested?

6. Time is of the essence when the Secretary or Deputy Secretary is waiting for us to respond to a Congressional request for information.

7. What’s In Your Toolbox? • INTERNET—Specific Sites??? • Employment Identification Number—required by IRS for all employers • Quality Assessment Review

8. PROGRAM TYPES There are six different types of apprenticeship programs defined as follows: JOINT LABOR MANAGEMENT PROGRAMS • Individual Joint (IJ): This type of program consists of an individual, single employer with a participating labor organization, where the Collective Bargaining Agreement addresses apprenticeship training. • Group Joint (GJ): This type of program consists of a group of employers with a participating labor organization, where a Collective Bargaining Agreement addresses apprenticeship training.

9. PROGRAM TYPES UNILATERIAL PROGRAMS • Individual Non-Joint (INJ): This type of program consists of an individual, single employer with no participating labor organization. • Group Non-Joint (GNJ): This type of program consists of a group of employers with no participating labor organization.

10. PROGRAM TYPES Waivers • Group Waiver (GW) – Employer group where either the employer group or the labor organization has voluntarily waived participation. • Individual Waiver (IW) – Individual employer where either the employer or the labor organization has voluntarily waived participation.

11. Steps to Register a New Apprenticeship Program • Determine what type of program it is, i.e., INJ, IJ, GJ or GNJ. • Contact information: name of POC, name of company, address, phone number(s), e-mail, etc. • Type of work/occupation(s). • Number of projected apprentices (for possible Affirmative Action Planand Selection Procedure). • Related training requirement of 144 hours and when,where and how this will be taken. • Wage scale-progressive wage scale required. • Work processes for their desired occupation(s). • Provide DOL apprenticeship pamphlets. • Does the starting wage meet the new Federal or State minimum wage?

12. Send Information to Potential Sponsor • Draft set of standards that apply to their company and 29 CRF 29. • Two draft blank wage scale forms (6-month & 1-year raises). • Affirmative Action, if required. • Samples of the work process(es) for their occupation(s). • Contact information for ATR.

13. Once the potential sponsor contacts our office, we then answer all questions by phone • Schedule visit date/time. • Have finalized (as much as possible) standards. • Review standards with company officials, such as ratio, related training provider, wage scale, AAP & SP(if needed), work process final with hours, whether paid/not paid for related training, etc. • Review administrative functions: Apprentice agreement form, transmission form (suspend/reinstate/cancel) and request for completion/certificate forms. Promote E-Registration at this time, for which we have a high success rate, and provide RAIS training. • Obtain company information, such as total employees, etc. (Form 2000 information). • Tour facility for operation, safety, etc. • Explain Compliance reviews (if applicable) and Quality Assessments.

14. Return to office actions • If routine (i.e., plumbing program) register program, do paperwork for presentation for final approval by State Director Delgado. • If “issues” with program, brief State Director and wait until given approval for registration. • Do Quality Review, check sheet, finalize standards package, attach RAIS information to Quality Review/Standards, Form 200, etc. for State Director review to ensure all required areas are covered. • After registration and signature by State Director, make copies, send to sponsor and file a copy. • Work with sponsor to register their apprentices (hopefully using E-Registration). • Answer any questions/monitor program status/operation.

15. STATE DIRECTORS REVIEW OF NEW PROGRAM/REVISION • Does the memo to the SD give a brief overview of key components? • Ratio as stated in CBA (if applicable) • Wages as stated in CBA (if applicable • Facilities information obtained from site visit • Number of apprentices • Is the 2000 (or applicable state form) complete? • Is the term of apprenticeship within the recommended hours as approved? • Is the SIC/NAICS code appropriate? • Is the Checklist attached and complete? (Circular 92-01) • If a joint program, did all parties adopt standards or sign waiver? • Are direct entry activities identified in the AAP? • It may be a nice gesture for an SD to send a letter to the new sponsor welcoming them to the National Apprenticeship System.

16. Letter to Sponsor • U.S. DEPARTMENT OF LABOR • OFFICE OF APPRENTICESHIP John Delgado, State Director • Birch Bayh Federal Building & U.S. Courthouse • 46 E. Ohio Street, Suite 528 • Indianapolis, IN 46204 • 317-226-7001 • September 11, 2007 • Lena Barkley • Project Director • CVS Regional Learning Center • 5901 Conner Road • Detroit, MI 48213 • Dear Ms. Barkley: • Your facility and you are to be commended for taking the steps necessary to register your training program with the Department of Labor, Office of Apprenticeship. Apprenticeship is the best training tool we can offer Hoosier workers today and is one that is recognized nationally. • By receiving this registration, your facility and you have agreed to all of the items included in the standards, work processes, and data contained on the Form 2000 (enclosed). Registration of an apprenticeship program is a worthy action, but it requires knowledge of and adherence to the requirements as outlined in the standards. Stephen Steed will be your Apprenticeship Training Representative (ATR) and if at any time there are questions, feel free to give him a call at 317-226-7002 or email at steed.stephen@dol.gov. • As a reminder, you can give up to 75% of your program hours as past education and training. As indicated when we met, this is your program and when you make changes to the wage scale, work processes or standards, please let us know. • Now that the registration process of your program has been completed you can use the supplied E-Registration package to register, request completions, or make changes in status. When registering an apprentice, you do need to make a copy of the registration form and after the apprentice and you sign it, file the form in their training folder. You can use the following numbers to sign into the RAIS system. • Your Sponsor Program ID Number is: IN070070022 Reference Number is: S59606 • Enclosed find the original registration certificate and copy of your standards as promised. Again, congratulations and we look forward to working with you in the future. If you have any questions, please call Stephen 317-226-7002 or e-mail at steed.stephen@dol.gov. • Sincerely, • John M. Delgado • State Director • Indiana and Kentucky • CC: Michelle Voll, Deputy Director • Felecia Hart, ATR, Washington, DC

17. Program Registration--RAPIDS

18. Program Registration--RAPIDS

19. Program Registration--RAPIDS

20. Program Registration--RAPIDS

21. REVIEW • Do Your Research—find out as much information as you can about the potential/new sponsor • Review New Sponsor’s Information in RAPIDS • Update Existing Sponsor’s Information • Keep Files Current