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What the Government Doesn’t Want You to Know…

… About Apprenticeship

In 2008, the Department of Labor, Employment, & Training Administration (ETA) revised the Labor Standards for the Registration of Apprenticeship Programs. Revisions to these standards are uncommon, but this time the ETA got it mostly right. The revisions were intended to promote quality control of training programs, and update current technology in training. The ETA wanted regulations that assured training providers were actually training their apprentices, therefore, the focuses on training providers were the completion rates of apprentices and the recordkeeping involved. The regulations are clear that if a training sponsor does not successfully complete the apprentice’s full training, the sponsor’s program could have its certification revoked. The ETA is looking for a long-term (four year) commitment from both the training sponsor and the apprentice.

The biggest challenge is the number of apprentices who voluntarily drop out of the program. It is common to see at least 50 percent of first year apprentices drop out. Their reasons for dropping out vary widely, but the effect is significant to the program. Considering this challenge, the ETA’s new regulation allows for a probationary period of up to twelve months or 25 percent of the length of the program, whichever is shorter. 29 C.F.R. § 29.5(b)(8) (2008). For example, a program that only lasted two years could have a maximum probationary period of six months, not a year. Any apprentices that drop out of the program during this period are not included in the program’s completion rate. §29 C.F.R. §29.6(d).

The probationary period for apprentices should not include their employment probation. If your company has a sixty-day probation for new hires, then you do not want to begin apprenticeship training until that time is completed. So you could say that day sixty-one of employment is the time to register and start training new apprentices. This is the first day of their apprenticeship probation.

Another significant revision in the new rules allows training sponsors to utilize modern technology, such as distance training, online training and correspondence training. 29 C.F.R. § 29.5(b)(4). This is good news to AFSA members because most of the training is done outside a formal classroom. The recordkeeping and documentation, however, must be correct and relevant to apprentice’s actual learning. The only significant change to the apprentice’s On-the-Job-Training (OJT) is the change in terminology to “on-the-job learning” (OJL). 29 C.F.R. § 29.5(b)(2).

AFSA receives several calls a year from training coordinators asking what is needed to start apprenticeship training. The best starting place to learn the process is AFSA’s publication Training Made Easy, which is available for download on our website firesprinkler.org. This up-to-date manual will provide details of starting and maintaining an apprenticeship training program. When it is time to talk to the appropriate state or federal agency, the training coordinator will be familiar with the terminology and specifications required.

Ultimately, the discussion will be about the Apprenticeship Agreement, which is defined in the Federal Register as such:

§29.2 Definitions. Apprenticeship agreement means a written agreement, complying with §29.7, between an apprentice and either the apprentice’s program sponsor, or an apprenticeship committee acting as agent for the program sponsor(s), which contains the terms and conditions of the employment and training of the apprentice.

Fortunately, the ETA or the State Apprenticeship Council (SAC) will provide a template for this agreement that requires no more than filling in the blanks. But don’t get too comfortable! There are still some things a training coordinator should know when filling in the blanks. In particular, four items sure be carefully considered before submitting the apprentice agreement to either the ETA or SAC. These four items are the probationary period, apprentice wage schedule, the ratio of apprentices, and On-the-Job-Learning.

Probationary Period

As discussed above, take advantage of the full twelve-month probationary period beginning at the signing of the apprentice agreement not the start of employment.

Apprentice Wage Schedule

An apprenticeship program is required to provide a wage schedule to reflect advancement in the program. 29 C.F.R. § 29.5(b)(5). The wage schedule applies to all projects the apprentices work on, whether it is government prevailing wage work or private work. Typically, apprentice training begins at 50 percent of the journeymen’s wages. Do not start lower than this because it will raise flags and slow down the approval.

Wage schedules can be set up as an annual progression or semi-annual.

An annual schedule could look like this:

  • Year 1: 50 percent of journeyman’s wage
  • Year 2: 65 percent of journeyman’s wage
  • Year 3: 75 percent of journeyman’s wage
  • Year 4: 90 percent of journeyman’s wage

A semi-annual schedule could look like this:

  • First six months: 50 percent of journeyman’s wage
  • Second six months 55 percent of journeyman’s wage
  • Third six months 65 percent of journeyman’s wage
  • Fourth six months: 70 percent of journeyman’s wage
  • Fifth six months: 75 percent of journeyman’s wage
  • Sixth six months: 85 percent of journeyman’s wage
  • Seventh six months: 90 percent of journeyman’s wage
  • Eighth six months: 95 percent of journeyman’s wage

Related Instruction and On-the-Job-Learning (OJL)

Related instruction in technical subjects concerning the occupation is recommended to be not less than 144 hours per year. 29 C.F.R. § 29.5(b)(4).

The AFSA Apprenticeship Training Program for Fire Sprinkler Fitters curriculum is designed to meet or exceed this standard.

OJL is an organized record of training that applies to the number of hours spent by the apprentice in work on the job in a time-based program; or a description of the skill sets to be attained by completion of a competency-based program. The on-the-job learning component details the minimum number of hours to be spent by the apprentice and a description of the skill sets to be attained by completion the program. 29 C.F.R. § 29.5(b)(2)(i-iv).

Ratio of apprentices to journeymen

The apprentice agreement must define the numeric ratio of apprentices to journeyman consistent with proper supervision, training, safety, and continuity of employment. The ratio language must be specific, and clearly described as to its application to the job. 29 C.F.R. §29.5(b)(7). Although most fire sprinkler contractors work with one journeyman with one apprentice, the ratio typically approved by ETA is one journeyman to the first apprentice, and three journeymen to each apprentice thereafter. When submitting a new program, it is advisable to submit a one journeyman to one apprentice ratio and then negotiate to an agreeable ratio.

AFSA has a long tradition of training fire sprinkler fitters, and offers the premier curriculum for training. If you have any questions about starting an apprenticeship training program within your company, or if you have any questions about apprenticeship call (214) 349-5965 or visit AFSA’s website at firesprinkler.org.

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