Dol Apprentice Agreement
Several commentators argued that there were gaps in the alternative thresholds proposed by the NPRM to determine learning opportunities in an area. Many commentators have argued that these numbers are too low; Many other commentators have argued that the numbers are too high. For example, one commentator recommended that, in the absence of a general exclusion from work, the ministry should use, on average, a threshold of 30,000 apprentices per year over the previous five years to identify areas where apprenticeship places in numbers are already large. On the other hand, one commentator argued that the exclusion standard unfairly discourages the “super-majority” of non-union construction training programmes because of the significant participation of trade unions in registered apprenticeship places. The commentator argued that the department could not claim that the reported apprenticeships adequately occupied an area when the number of apprentices in this sector is less than 50 per cent. Other commentators said that the formula was illogical and unnecessary and that it had to be eliminated. One commentator argued that the proposed rule does not solve many problems, such as challenges. B employers in terms of navigation in the learning system, lack of attention to reciprocity and uncertainty of trainees regarding the evaluation of program quality. Several commentators suggested that each SRE and IRAP candidate be classified as page 14300 printed at start-up in accordance with the codes of the U.S. Industry Classification System (NAICS) or the Occupational Information Network (O-NET).
The Department recognizes that the estimate of the number of SRE applicants using the IAAI grant program is subject to data protection restrictions and uncertainties. However, as no other data source was proposed as part of the public comment process, the department retained its methodology and data source to estimate the number of ERS applicants. With respect to the 5% growth rate, the department notes that this is a reasonable estimate, given that up to 50 occupations are ripe for developing apprenticeships  and that this regulation aims to extend the learning model widely, including for employers and workers who had not previously considered participating. One commentator said that the proposed regulations would help address the current shortage of skilled labour in the craft and crafts sector, as well as the costly and time-consuming delays in the current apprenticeship admission process. The commentator explained that 90% of trainees have a job and a salary increase of $300,000 at the end of their programme, but only 0.3% of the workforce have participated in registered apprenticeship programmes, partly due to the lack of flexibility under the registered learning model. The ministry is opposed to the concern that the ability of SREs to adapt their practices to each state and city where they certify programs would result in different certification qualities and therefore refuse to prohibit such an approach. On the contrary, the Department anticipates that ERS will make these adjustments out of necessity in order to act successfully in a state or region. For example, an apprentice who works in auto body repair in the southwestern United States may not have to be competent to repair the damage caused by dispersed salt that may be common in other parts of the country.