IRAP Message Guidance

Message Guidance 

The federal Department of Labor (DOL) has released new regulations governing Industry Recognized Apprenticeship Programs (IRAPs).  IRAPs would pose a major threat to our union apprenticeship system if they become recognized in the construction industry.  The proposed rule would currently make our industry exempt from IRAPs, but anti-union interest groups are pushing to eliminate the exemption.  

This is the largest threat against the building trades from a presidential administration in more than a generation, and we must take it seriously.  This campaign to save our apprenticeships will only succeed with fast and successful action by local unions. 

What are IRAPs, and how will they hurt us?  IRAPs are loosely-regulated training programs that do not require the same quality of instruction, pay scales or journeyman graduation rates as our federally registered union apprenticeships.  If IRAPs enter the construction industry they will undercut our apprenticeships all over the country, costing us work to the nonunion sector and making every jobsite less safe.

Therefore, our goal is to keep the construction industry exempt from the IRAP rule.

Registered Apprenticeship vs. Industry Recognized Apprenticeship 

Registered Apprenticeship

  1. Clearly defined criteria for registering an apprenticeship program
  2. Strict standards apply to all federally registered apprenticeship programs
  3. Heavily regulated by the Dept. of Labor
  4. Must provide proof of journeymen graduation rates
  5. Nationally recognized certifications and credentials
  6. Require safety training
  7. Pay a living wage
  8. Admissions standards comply with anti-discrimination policies and fair hiring practices
  9. Current union apprenticeship programs


  1. Loosely defined criteria for a program to qualify as an apprenticeship
  2. Lax standards; let the buyer beware
  3. Minimal oversight by the Dept. of Labor
  4. No graduation or completion requirements
  5. No widespread recognition of certifications or credentials
  6. No requirement for safety training
  7. No wage guarantees
  8. Exempt from the anti-discrimination policies and fair hiring practices our programs have
  9. Just a rebranded nonunion open-shop training program

Top Message Points

These are the top message points that everyone should use:

  1. Each of us worked hard to earn our credentials.  IRAPs will flood the industry with cheap, unearned certs, devaluing ours in comparison.
  2. Nonunion contractors can pay IRAP students minimum wage, not apprentice scale.  IRAPs will drive down wages.
  3. Nonunion contractors will use construction IRAPs to undercut us on bids and take our work.

Political coordinators and apprenticeship trainers have other message frames that they should deliver as well:

Political Coordinators

PCs are authoritative messengers on how this regulation works and how we will fight it.  Emphasize that this is an attack on our union and we need to stick together to beat it.  Be ready to answer questions about how the rule works.

Talking Points

  1. Ironworkers take pride in our training programs because we’re the best in the business. Our programs are tried, tested and proven true to produce highly skilled craft professionals.  With IRAPs in construction, nonunion contractors would hand out certifications without bothering with the same training standards.
  2. This rule change is a blatant attack on our union by the same interest groups that passed right to work in places like Wisconsin and Indiana.
  3. IRAPs are a tool for nonunion contractors to encroach on the union market. Union ironworkers’ jobs are at risk. 


Apprentice Coordinators

ACs and instructors are trusted authorities on quality of training and safety.  They should emphasize how IRAPs will devalue our skill certifications and the risk to life and limb of untrained workers on the jobsite.

Talking Points 

  1. Unlike registered apprenticeship programs, there are no universally respected criteria in place to evaluate the skills or shortcomings of credentials issued under the IRAP system. This muddies the water and dilutes the strength of certifications and upgrades that set union ironworkers apart from the competition. 
  2. In addition to training the best ironworkers in the business, our union’s training programs are designed to produce the safest workplaces around. Worksites with IRAP contractors will be less safe.
  3. Stringent safety standards are essential in the construction industry. The best way to ensure workers are safe on the job is to continuously train on the proper precautions, equipment and first aid treatment over the course of a registered apprenticeship program. 
  4. Registered apprenticeship programs like the Iron Workers’ training program are the best way to prepare for a career in the construction industry. Not only are apprentices exposed to hands-on training and classroom instruction, but they receive input from some of our industry’s most responsible business leaders. 



  1. Don’t make this an attack on Trump.  If you do, you will turn off Trump supporters to this issue.
  2. Don’t lose focus. Every comment should ask the Department of Labor to keep the construction exemption in the final rule.
  3. Don’t get tripped up by the fact that the draft rule has an exemption for construction.  The final rule doesn’t have to keep it, and anti-union lobbyist are working right now to remove it.  
  4. Don’t worry about getting your message perfect. This is not a tough sell; we are defending beloved apprenticeship programs from Washington bureaucrats and lobbyists. This message guidance has worked well for us, but feel free to experiment and find a message that fits you.