1. TIME IS RUNNING OUT
FOR SMART LOCAL UNION USE ONLY

2. Union Apprenticeship Programs Are In Danger
In June, the DOL proposed regulations to implement Industry-Recognized Apprenticeship Programs (IRAPs).
Unlike the Registered Apprenticeship model, IRAPs puts the fox in charge of the henhouse.
The new IRAP system will give private organizations, such as employers and trade associations, free rein to create new watered-down standards and certify subpar apprenticeship programs.

3. We Need to Make the Construction Industry Exclusion Permanent
The proposed IRAP regulations provide a temporary exemption for the construction industry.
But this could change when the DOL issues the final version of the regulation.
We need to make sure that when the final regulations come out, the construction industry exclusion is permanent.

4. IRAP Mean Lower Standards
If IRAPs are introduced into the construction industry, it will take 15 minutes for anyone with a P.O. Box number anywhere in the world to register an apprenticeship program to compete with the current model.
These programs will be unregulated, with no oversight.

5. Registered Apprenticeship Programs Set A High Bar
Construction registered programs recruit, train and retain workers through progressive wage increases.
Apprentice-to-journeyworker ratios promote safety.
Quality assurance assessments are provided by the government.
Uniform standards to ensure all apprentices receive top- notch training.
Mandatory safety training.
Instructor eligibility requirements.
Transparency requirements.

6. IRAPs Will Destroy Industry Standards
IRAPs do not need to follow any of the same rules as registered apprenticeship programs.
All they need is a P.O. Box number, an internet connection and “apprentices” paid the minimum wage.

7. Powerful Forces Are Looking to Destroy Union Construction
The Associated Builders and Contractors, National Right to Work Committee and others are working with “swamp” allies in Washington to bring IRAPs into the construction industry.
James Sherk, a former leader at the Heritage Foundation, US Chamber and now a labor and employment adviser at the White House, has already bragged he will be “the man to kill off the construction unions” by championing IRAPs in construction.
He is joined by White House Chief of Staff Mike Mulvaney, who has his own agenda to help anti-union groups.

8. The Clock Is Ticking
In a compromise to anti-union groups who were disappointed to see the construction industry excluded from IRAPs, the DOL allowed comments on whether or not IRAPs should be included in the industry.
The ABC, National Right to Work Committee and other anti- union groups pledged to send comments in to the Dept of Labor on the construction exemption.
The deadline for comments is August 26.

9. A World Without Union Apprenticeships
If the ABC and non-union groups succeed, IRAPs will be included in the construction industry.
Non-union “apprentices” will be used to bid on prevailing wages jobs and swamp jobsites normally staffed by union members.
The downward effect on union wages, benefits and safety will be devastating.

10. The DOL Needs to Hear From Us!
Text the word APPRENTICE to to submit a comment via your mobile phone. (Message and data rates may apply).
Visit our special landing page at to submit a comment directly to the Dept of Labor.
Encourage all your family, friends and fellow members to submit comments.
After August 26 it will be too late.