The contractor shall develop on-the-job training opportunities and participate in training programs that are relevant to the contractor’s employment needs and are intended to upgrade the skills of its workers. These programs and opportunities must expressly include minorities and women.213 Examples of possible programs and opportunities include apprenticeships and trainee programs relevant to the contractor’s employment needs, especially those programs the U.S. Department of Labor funded or approved.214
To evaluate the contractor’s compliance with this specification, COs must:
- Determine whether the contractor has developed and conducted any training programs and, if so, whether it has provided notice of these programs to its recruitment sources. Obtain copies of any letters informing recruitment sources or schools of training programs, including those to minority and women sources. Get the names of applicants that the contractor referred to the programs. Determine whether the contractor has employed and trained anyone below the journey level. If it has, describe what was done.
- Determine which trades are covered by formal apprenticeship programs (typically found in projects utilizing union labor) or other types of formal training programs not associated with trade unions. When either type of program is in place, a CO must determine the participation rate of minorities and women.
- When there are no formal programs for a particular trade, determine what, if anything, the contractor has done to provide on-the-job training, and the extent to which that training was made available to minorities and women.
- If the contractor provides on-the-job training, determine whether minorities and women have equal access to training in all trades. Determine whether minorities and women are performing all aspects of their trade or if the contractor is repeatedly assigning them to the same task.
- Determine whether the contractor has records of cash contributions, equipment supplied or contractor personnel provided as instructors for Office of Apprenticeship approved, or U.S. Department of Labor funded, or other training programs.
- Determine whether the contractor has records of specific hiring and training of workers from such programs. The CO should also determine the results of the contractor’s efforts (e.g., number of workers trained identified by race, ethnicity and sex, hours worked, hours trained, relative compensation, trade) and record the results in the report.
213. 41 CFR 60-4.3(a) paragraph 7, step e.
214. See Item III.B.1. of the Construction SCER. Refer to 41 CFR Part 60-20, 41 CFR 68-4.3(a) paragraph 7, step e and Part III.B of the Construction SCER.