Advancing Equity: The Case for Updating Apprenticeship Programs

By Diane Harris and India Heckstall

Earlier this year, the U.S. Department of Labor (DOL) issued a notice of proposed rulemaking (NPRM) to update the National Apprenticeship System to align registered apprenticeships to the evolving needs of workers, employers, and the economy. The NPRM seeks to make apprenticeships more accessible and to recruit and retain workers from communities facing increased barriers to access. If implemented, these rules would be the first significant update to the program in sixteen years.

CLASP and partners such as the National Taskforce on Tradeswomen’s Issues expressed support for the proposed changes geared toward enhancing accessibility for women and workers of color. However, these advocacy organizations also raised concerns regarding the absence of a living wage, flexible exceptions for minimum hours, and costs of end-point assessments.

At the same time, dissenting views authored by the Tennessee attorney general and signed by the attorney generals of 23 other states challenge the NPRM’s DEIA (Diversity, Equity, Inclusion, and Accessibility) initiatives, claiming that the agency cannot pursue equity measures by “engaging in racial discrimination.”

Calls for race-blind strategies in education and workforce development are not new, but they overlook the crucial distinction between equality and equity. While seemingly neutral, these approaches fail to address structural racism and perpetuate existing disparities.

Understanding the Value of Apprenticeships

Apprenticeships offer quality pathways to careers in various industries, blending on-the-job training with classroom instruction. This approach equips individuals with the skills, knowledge, and industry-recognized credentials necessary for their careers and fosters upward economic mobility. Apprenticeship programs also benefit the wider economy by addressing labor market demands and strengthening specific industries and offer economic security and benefits to the apprentices themselves.

The majority of individuals who complete a registered apprenticeship begin their careers with higher salaries, with an average annual salary of $80,000. In contrast, American workers that have not gone through an apprenticeship program earn, on average, 18 percent less per year ($65,470) and workers without college degrees earn less than half that salary ($34,430) annually. Research also indicates that apprenticeships increase an individual’s earnings across occupational sectors and demographics.

Efforts to Increase DEIA Efforts in Apprenticeship Programs

The under-representation of women and workers of color in apprenticeships underscores the need for robust DEIA initiatives within these programs. Despite comprising nearly half of the workforce, women account for a small portion (12.82 percent) of active registered apprentices, while Black registered apprentices comprise only 10.67 percent. These disparities extend to wages, with Black apprentices earning less than their white, Latino, and Asian counterparts both at the start and conclusion of their apprenticeships.

Moreover, these wage gaps persist after the program, with white workers experiencing slight wage improvements while Black workers see their earnings decrease. These realities highlight the critical importance of moving beyond race-blind measures to promote apprenticeship programs that are accessible to workers of all backgrounds.

Recognizing this urgent need, the DOL has proposed revisions to the regulations to enhance worker protections and improve program quality. They emphasize embedding equity at the core of registered apprenticeships and includes several key provisions:

  • Requiring sponsors and stakeholders to develop strategies for recruiting and retaining individuals from underserved communities.
  • Mandating State Apprenticeship Agencies (SAAs) to submit detailed plans for advancing DEIA to the Office of Apprenticeship.
  • Directing SAAs to collect and report individual demographic data on apprentices to track equity-related outcomes.
  • Implementing measures to ensure compliance with DEIA initiatives.

The proposed rule addresses the need for new apprenticeship programs to prioritize accessibility and equitable recruitment in their communities. It promotes accountability through the submission of actionable plans and the collection of disaggregated data, enabling policymakers, advocates, and constituents to assess equity standards in program administration and outcomes.

Criticism of NPRM’s Equity Measure

There are significant potential benefits of the rule, yet it faces equally significant challenges. Submitted comments from 24 states argue that the DOL’s aim of embedding equity into registered apprenticeships effectively engages in racial discrimination by favoring individuals based solely on their race and oversteps legal boundaries.

Despite this concerted effort to derail updates that address current racial disparities, it is critical that the pursuit of fairness and inclusivity within registered apprenticeship programs remain a paramount objective. There is a fundamental need for equitable opportunities and access to apprenticeships; therefore, it is imperative to maintain a steadfast commitment to fostering genuine equity and opportunity within the apprenticeship landscape.


By embedding DEIA principles into apprenticeship standards, opportunities become accessible to all, regardless of background. But promoting DEIA in apprenticeship programs is an economic imperative as much as it is a social justice issue. Fostering a diverse workforce drives innovation and productivity and creates a more inclusive and prosperous society. It is incumbent upon policymakers, employers, and stakeholders to maintain a steadfast commitment to DEIA principles for shaping a more equitable future.