SMART Members Contribute to Historic Number of Comments Submitted to the DOL against IRAPs

North America’s Building Trades Unions called effort to submit comments to the U.S. Department of Labor against Industry-Recognized Apprenticeship Programs, also called IRAPs, record setting.

In an Aug. 27 prepared statement, NABTU said nearly 325,000 Americans told the DOL they do not support IRAPs in the construction industry. The number of submitted comments broke the previous record of 25,000 submitted on changes to overtime pay.

According to a statement on the SMART website, SMART members submitted just over 18,000 comments to the DOL, with several thousand more comments submitted by friends and family members.

“This historic number of nearly 325,000 comments submitted by working men and women across the United States, makes it clear that construction workers don’t want the federal government to cut wages and destroy jobs in a dangerous economic experiment,” said NABTU President Sean McGarvey. “The message from Michigan to Florida, from Pennsylvania to New Mexico was absolutely clear: they don’t want the swamp to undermine their standard of living and the opportunity for future generations to realize the American Dream.”

In a 60-day window from June 28 through Aug. 26, hundreds of thousands of Americans were educated on the dangers of IRAPs and voiced their opinions on why they do not belong in the construction industry.

Unlike the building trades registered apprenticeship program, IRAPs would allow private organizations, such as employers and trade associations, the ability to create their own apprenticeship programs, but not be subject to the same stringent regulations as registered programs.

IRAPs differ from registered apprenticeships because they are not regulated by the government and give employers, including anti-union contractors affiliated with the Associated Builders and Contractors, the ability to train construction workers without any regulations or governmental oversight.

This means they do not have to follow the same rules as registered apprenticeship programs, creating a race to the bottom in terms of training.

If IRAPs are allowed, they could cause irreparable harm to registered apprenticeships found within the union construction industry and cost journeymen jobs.

IRAPs will lead to a reduction in wages, the cutting of corners, a reduced standard of safety and lower work quality. IRAPs would even allow contractors creating a permanent class of apprentices, who would only be paid minimum wage. These same contractors could then bid on jobs against union contractors using only apprentice-level workers, not trained journeymen.

NABTU and building trades unions such as SMART are concerned the temporary rule may be removed when the DOL issues the final version of the regulation and allow IRAPs in construction instead of making the industry permanently exempt.

The push to keep IRAPs out of the construction industry was spearheaded by the NABTU, which worked with their affiliated International Unions, including SMART, to help educate their members, contractors, families, friends and other Americans.

“Our members do not stand alone,” McGarvey said. “Through this comment period, contractors, industry leaders, project owners, educators, safety and training professionals, investors, community advocates, faith leaders, environmental stewards, veterans, State Apprenticeship Agencies and overwhelming bipartisan majorities in Congress have spoken in one voice: IRAP’s have no place in the construction industry.”

There is no timeline for the DOL to make a ruling on the final IRAP proposal.

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