Frequently Asked Questions 

  • Why have I never heard of an IRAP before? “Industry Recognized Apprenticeship Program” is a made-up term that anti-union interest groups and their friends in the Department of Labor are using to create a way to recognize subpar, fly-by-night training programs in the construction industry.
  • How does this regulation work? The federal Department of Labor (DOL) has published a draft version of the rule and is now accepting comments from the public. Once the comment period ends DOL will take several months to release the final rule. DOL may remove the construction exemption from the final rule without warning, so we cannot let our guard down.
  • What is our plan? If thousands of union ironworkers mobilize to comment on the rule, it will be proof that we can turn out voters to defend our apprenticeships. The International will help local unions get as many members as possible to comment. After this show of strength, we will continue to lobby aggressively in target states to keep the heat on the administration.
  • How do members comment? Stop by your local union hall to submit a comment in person, attend a comment bank, or visit Each person can comment only once, and form letters will not be accepted.
  • What’s the difference between personal comments and online? Every local must collect personally written comments by holding comment banks, visiting worksites and recruiting members at dispatch. These will have the most impact on the DOL and ensure that members are educated on the issue. Ironworkers who cannot get to the hall may submit semi-customized comments at
  • Can you comment more than once? No, but you can still act. If an ironworker has already commented to the DOL, have him or her write a letter to their U.S. Senator.
  • What do I do with the comments I’ve collected? Written comments, along with the completed sign-in sheet, should be scanned and emailed to immediately following each comment bank. Do not delay and do not stockpile comments – there is no minimum or magic number to reach.
  • I signed a petition against IRAPs. Is that a comment? No, ironworkers who signed an online petition should still comment, either at their hall or at
  • Can my friends and family comment? Yes, ironworkers are encouraged to bring their families to local comment banks, bring home comment forms or have their families visit