Acting as the precision metalworking industry’s One Voice in Washington, DC, NTMA’s lobbying and strategic communications firms have been working tirelessly to ensure your voice is heard on Capitol Hill and projected by the media.
In the latest machining news, the Department of Labor (DOL) has proposed significant rule changes that could impact the way manufacturers train apprentices for tool and die making, machining, sheet metal fabrication, and other related career paths.
In a Notice of Proposed Rulemaking (NPRM), the DOL announced plans to “modernize registered apprenticeship regulations.”
Overview: Proposed Changes to the National Apprenticeship System
| National Apprenticeship System Enhancements | Download the PDF |
| Docket Number: | ETA–2023–0004 |
| Regulatory Identification Number: | RIN 1205–AC13 |
The DOL’s proposed new rule would enact the first changes to the National Apprenticeship System since October 29, 2008.
Under the 2008 rule, companies are permitted great flexibility in structuring their apprenticeship programs, which is why today’s training programs apply a range of methodologies:
- Time-only programs measure training hours
- Time-plus-competency programs measure training hours and pre-existing knowledge
- Competency-only programs measure pre-existing knowledge
Here at NTMA, we are primarily concerned that, under the new rule, the federal government will only recognize time-based registered apprenticeship programs with a minimum of 2,000 on-the-job (OJT) training hours, of which 144 must be classroom hours.
The Data: Why Apprenticeships Matter in Manufacturing
Before we dig deeper into the DOL’s proposal, let’s take a look at the data:
NTMA members cite “workforce development” as the #1 concern
Since 2012, NTMA members have called out workforce development as their primary business concern. And with 77% describing their recruiting challenges as “severe” or “moderate,” it’s no wonder machine shop organizations are worried.
50% of NTMA member shops offer apprenticeships
Of the approximately 50% of NTMA member shops offering apprenticeship programs, 60% of those programs qualify as Registered Apprenticeships (RAs). RA programs unlock federal and state funding for CNC machine businesses; they also receive recognition through education organizations and workforce investment boards, which help draw the attention of training organizations, students, and parents.
Manufacturers cannot afford to lose RA status for competency-inclusive apprenticeships that have already proven successful in workforce development.
Only 12.63% of manufacturers are under 30
In 37% of NTMA member shops, the average employee is 51 years old or older. With so many skilled workers nearing retirement age, manufacturing businesses desperately need younger workers. However, manufacturers under age 30 account for only 12.63% of today’s workforce, down from 16% one year ago.
When a machine shop organization is lucky enough to recruit a young apprentice, it’s in everyone’s best interest to help that individual advance quickly. Manufacturers cannot risk losing younger apprentices due to time-based requirements that slow their career growth.
Why We’re Worried: Competency vs. Time
Many of today’s registered apprenticeship programs are what we call “competency-based” apprenticeships, an allowance we fought to achieve back in 2008.
The current competency-inclusive options allow apprentices to “test out of” a program instead of enduring thousands of hours of classroom time they may not need. This flexibility not only benefits the apprentice but also the business by potentially fast-tracking skilled apprentices into full employment positions.
Competency-inclusive apprenticeships allow companies to provide incremental wage increases as apprentices reach new milestones and are, therefore, more appealing to prospective employees.
Today’s manufacturers need the flexibility to recruit, train, retain, and continuously upskill. If a CNC machine business is locked into a time-based apprenticeship program, it loses the flexibility necessary to compete in the global marketplace.
Time-only apprenticeships track only one metric: time. Until an apprentice has met that singular goal, that individual cannot advance.
Are There Any Advantages to the New Proposed Rule?
The new proposal would still allow Registered Apprenticeships to enroll apprentices as young as 16, only now they would enroll under a new apprenticeship category called Career and Technical Education (CTE) Apprenticeship, which would formalize youth-oriented apprenticeships with a modified, time-based apprenticeship program. CTE courses could be beneficial if implemented without hindering or halting the programs that have already proven successful.
What Prompted the New Proposed Rule?
As we see it, the primary reason for the National Apprenticeship System to institute a new rule is logical: the current, flexible system is difficult to audit.
With numerous programs and measuring methods, maintaining one consistent auditing approach is practically impossible. By better streamlining the National Apprenticeship System, the federal government hopes to establish a uniform comparison metric, making it easier for regulators to assess a program’s success and assign funding.
While the intent may be sound, the fact remains that a one-size-fits-all approach cannot serve the diverse needs of countless high-skill industries.
How NTMA Is Responding
The DOL is accepting comments on the proposal through March 18, 2024.
Here at NTMA, we’re formulating our comments to focus on the inflexible 2,000-hour requirement, a rule that, according to some NTMA members, will “set manufacturing apprentices back 20 to 30 years.”
As we refine our comments in preparation for the March submission deadline, we encourage you to contact NTMA with your feedback.
NTMA: Your Voice on Capitol Hill
What happens in Washington matters to small and medium-sized businesses! In an industry built on local shops and family-run businesses, our success depends on our collective fight for policies that enable growth and empower advancement.
From NTMA’s participation in National Apprenticeship Week to our ongoing interaction with the White House on issues surrounding workforce development, we exist to advocate for you, your employees, your shop, and your future.
