IRAP Announcement Opens Comment Period to USDOL


A USDOL announcement has opened a 60-day public comment period in which individuals and organizations from across the country can weigh in on the proposed rule change.

Published jun. 28, 2019

This week, the U.S. Department of Labor announced a Notice of Proposed Rulemaking (NPRM) that would include industry-recognized apprenticeship programs (IRAPs) within the federal regulations governing the National Apprenticeship Act. This filing has opened a 60-day public comment period in which individuals and organizations from across the country can weigh in on the proposed rule change.

JFF urges all apprenticeship stakeholders to review the proposed IRAP rule and submit written comments by August 26, 2019.

Since the introduction of the IRAP concept, there has been some confusion and concern in the field about creating another form of apprenticeship. What will be the impact on Registered Apprenticeships (RAs)? What fees will be involved for participating organizations? How will conflicts of interest be mitigated? What oversight will there be from DOL? What quality and outcomes can be expected?

At the same time, others have touted the potential for IRAPs to provide flexibility and a less onerous approach to apprenticeship implementation.

The DOL’s proposed rule would formally include IRAPs in the Code of Federal Regulations (29 CFR Part 29) that govern the RA system under the National Apprenticeship Act of 1937.

Additionally, the rule aims to establish a process to authorize third-party “Standards Recognition Entities (SREs)” that would recognize IRAPs. The proposed rule describes what entities may become SREs; what their responsibilities and requirements would be; hallmarks of the high-quality apprenticeship programs they would recognize; and how the administrator of the Office of Apprenticeship would interact with them. The rule also describes how IRAPs would operate in parallel with the RA system.

This proposed rule change is an important moment that will affect the future of apprenticeship in the United States. It is critical for those in the apprenticeship field to provide their knowledge and expertise during this comment period. We encourage you to read the rule and to submit your comments and concerns to the DOL by August 26.