Final Rule On IRAPs

On March 11, 2020, the Department of Labor (DOL) published the final rule on “Industry-Recognized Apprenticeship Programs” (IRAPs). The final rule addresses many of the concerns raised by BAC in our opposition to IRAPs. Most importantly, the final rule exempts the construction industry from the IRAP system, and further this permanent exemption does not sunset.

BAC, in conjunction with the National Building Trades, worked on a coordinated campaign to ensure that the Trump Administration was aware of the serious concerns that construction workers had regarding the threat IRAPs posed to the Registered Apprenticeship system. Ultimately, this collaborative effort produced over 300,000 comments to DOL that played a large part in ensuring that the final rule recognized the value that union construction apprenticeship programs bring to our industry, and society at large. The Executive Board wants to thank all those local leaders and members that took the time to file comments with DOL in opposition to the misguided effort that sought to disrupt the apprenticeship system that generations of BAC members relied upon.

While we were successful at influencing the final IRAP rule, we must remain vigilant. The IRAP model creates a parallel training system using the term “Apprenticeship,” but with few standards and no meaningful oversight. We do not doubt that the ABC and other anti-union forces will continue their efforts to expand the misguided IRAP system wherever, and whenever, possible. Accordingly, we must be prepared to make our voices heard when necessary.

As the 2020 elections approach, we must work hard to ensure that politicians seeking our support are equally supportive of the programs and priorities established by unions that provide our members the services and voice in their work life that they rightfully expect.

Thank you again for your commitment to this fight.


Tim Driscoll, President, International Union of Bricklayers and Allied Craftworkers