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Home » MCAA Responds to DOL Proposal to Create IRAPs

MCAA Responds to DOL Proposal to Create IRAPs

August 7, 2019
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MCAA Responds to DOL Proposal to Create IRAPs

The MCAA recently sent a letter to the Department of Labor concerning the department’s plans to establish “industry-recognized apprenticeship programs.”

The trade association along with the employment base of the Plumber and Pipefitters Union represents some 320,000 workers long trained traditionally in more than 240 jointly administered registered apprenticeship training programs throughout the country.

Currently, the construction industry is exempt from the proposed DOL rule. The MCAA is concerned, however, that the exemption might not be permanent.

In a letter signed by John McNerney, MCAA’s general counsel, to Adele Gagliardi, administrator of the DOL’s office of policy development and research, MCAA outlined its comments under the following categories:

  • Categorical support for permanent exemption of construction industry registered apprenticeship programs from SRE/IRAP Conflicts.
  • Inconsistencies between the task force on apprenticeship expansion recommendations and the proposed regulations.
  • Other aspects of the possible conflict between IRAPs and registered apprenticeship programs and “deconfliction” procedures.
  • Unexamined assumptions that traditional federal and state registration procedures are rigid and inflexible; potential IRAP erosion of SAC standards.
  • Lack of important and explicit apprentice welfare safeguards in various aspects of SRE program development requirements.

You can read the letter in full here.

 

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