How do I complete step 4?

Step 4: Hold EEO Information Sessions and Anti-Harassment Trainings 

We cover four aspects of EEO information sessions and anti-harassment trainings in this module:

1. Required audiences
2. Frequency and timing
3. Considerations for youth apprenticeship programs
4. Content of sessions and trainings

1. Required audiences

For both the EEO Information Sessions and the Harassment-Prevention Training, the required audiences include the apprentices and all individuals connected with the administration or operation of the apprenticeship program who regularly work with the apprentices, including:

Journeyworkers/mentors
Foremen and supervisors who establish accepted practices on the job site
Hiring officials
Teachers/instructors
Guidance counselors

For many—if not most—RAPs, involving all these audiences presents a logistical challenge because the audiences are employees of different entities. For example, if the sponsor is a Joint Apprenticeship Training Committee, the people who assess candidates for admission to and completion of the apprenticeship and the apprentices’ classroom instructors are employees of the JATC or union, but the people who hire the apprentices and who supervise and train them on the job are employees of the participating employer(s). 

One way to handle this is to hold some or all of the EEO sessions and anti-harassment training virtually. Of course, in-person sessions are more effective for communicating and teaching. But we are all learning how to substitute online communications and make them as effective as possible. OA has developed a suite of materials that you can adapt for your online anti-harassment trainings (see below).  

Pro tips:  

When using online training, develop a mechanism that all the relevant entities can use to verify that the trainees actually completed the training.
Work out procedures for holding the EEO information sessions and anti-harassment training, and ensuring that the required audiences attend them with all the relevant parties when you first set up the apprenticeship program. Also, include them in the written agreements between the RAP sponsor and the participating schools and employers, so that everyone knows what they are expected to do. 

2. Frequency and timing

The Apprenticeship EEO regulations do not prescribe any particular frequency for holding either the EEO information sessions or the anti-harassment trainings. But both need to be provided frequently enough to ensure that all apprentices, journeyworkers, and other personnel connected with the administration or operation of the apprenticeship program receive it. Since there’s always staff turnover and, in an apprenticeship program, new apprentices are indentured periodically—in school-based programs, perhaps as often as every semester—it makes sense to hold these sessions/trainings whenever there is a critical mass of new apprentices or staff.That said, once a year is probably not enough to be effective. EEOC’s Sexual Harassment Task Force reviewed the research and found that:  

If anti-harassment trainings are held once a year (or once every other year), employees will not believe that preventing harassment is a high priority for the employer. Conversely, if anti-harassment trainings are regularly scheduled events in which key information is reinforced, that will send the message that the goal of the training is important.

The EEOC further found that “[anti-harassment training] is one area where, in general, repetition is a good thing.”

3. Considerations for youth apprenticeship programs

Several of these requirements may present added logistical challenges for in-school youth apprenticeship programs. 

First, fulfilling the requirement of training all the people who “regularly work” with the apprentices may be challenging because, by definition, an in-school youth apprentice program involves several entities—at least the high school and the participating employer(s), and possibly also a community college, nonprofit, and other entity that sponsors the program—and the people who “regularly work” with the apprentices are actually employees of these various entities. There isn't one company that can simply hold one training session for all of its relevant employees—the sessions have to be coordinated across the various entities or provided separately by all of them.

Timing and frequency may also be a logistical challenge for in-school youth apprenticeship programs because they have to mesh the EEO policy sessions and anti-harassment trainings with the school calendar. For the apprentices—that is, the students—it would make sense to include that content in the communication of classroom norms and building of classroom culture that are often covered in the first few days of each semester. It would be even better to embed the EEO content in the regular instruction and make it an integral part of classroom culture. Perhaps it is possible to include faculty and staff who interact with apprentices, and even the journeyworkers and supervisors with whom they work on the job, in this part of the curriculum as well.

4. Content for sessions and trainings

The minimum content of EEO information sessions:

• Communication of the sponsor’s EEO policy

The minimum content of anti-harassment training:

• Clear statement that harassing conduct will not be tolerated
• The definition and examples of harassment 
• How an individual can file a harassment complaint with OA

In-person and online training program guide for anti-harassment training

As mentioned above, OA has posted a suite of resources that can be used for anti-harassment training, including a training program that offers two options—one for in-person training and one for online training. By following one of the two options, apprenticeship sponsors will meet the requirements laid out in the Apprenticeship EEO regulations regarding anti-harassment training. There is also a guide for using and customizing the materials.

PowerPoint presentation for anti-harassment training

OA recommends that programs provide in-person, facilitated training, and offers a PowerPoint presentation that can be used for that purpose. The PowerPoint presentation dives into the types of unlawful harassment that can occur at a workplace and what employees can do to stop it.It also includes a variety of real-world scenarios and related discussion questions that can be tailored to each sponsor's environment.

The presentation also provides a place for sponsors to include contact information for the individual or office that apprentices and apprenticeship applicants should contact in the event that they experience or witness harassment in the program. The presentation can be customized to include the sponsor's logo or other information.

Training video: Intro to anti-harassment in apprenticeship programs

As an alternative, OA offers a short video that RAPscan combines with the PowerPoint slides (video provided by DOL/OA). The video covers the definition of unlawful harassment, who may be a target or perpetrator of harassment, and what to do if an apprentice or other employee experiences or witnesses harassment.

The video can also be used as part of self-directed, web-based training. Watching the video and taking the Online Knowledge Assessment (see below) meets minimum regulatory requirements. Take a moment to watch the video. It’s only six minutes long.

Online knowledge assessment

This component, Checking Your Knowledge on Unlawful Harassment in Apprenticeship Programs is a web-based quiz. Viewers of the video take a short series of interactive knowledge checks to assess their understanding. It can also be used with the PowerPoint.

This quiz is designed to meet the regulations' requirement that the sponsor-provided anti-harassment training includes participation by trainees, even if the video is not viewed at an in-person meeting or training session. The knowledge assessment can also be adapted for in-person trainings.

• Now that you’ve viewed the video, test your knowledge about unlawful harassment by taking the quiz.

Supplemental fact sheet: for those who manage, train, and mentor apprentices

Addressing Harassment in Apprenticeship: A Fact Sheet for Those Who Manage, Train, and Mentor Apprentices, is a fact sheet to give to journeyworkers, forepersons, frontline supervisors, and others who manage, train, and mentor apprentices. It outlines their responsibilities in addressing workplace harassment, including tips for creating a safe and inclusive workplace for all.

Supplemental fact sheet: for apprentices

Unlawful Harassment in Apprenticeship: A Tip Sheet for Apprentices contains the highlights of the training program. To use it, customize it with information on whom to contact in the event that an apprentice or apprenticeship applicant experiences or witnesses harassment in the program. You can also include your contact information at the end. 

Note that merely providing this document does NOT meet the requirement of providing interactive training. 

Your next step

At the end of each of the five steps, we will ask you to record your next step using prompts from the course expert. Why? So you can walk away from this course with tangible things you need to do next. You can either record your answers for step 4:

• In this Road Map,
• Right within Canvas by clicking TAKE THE SURVEY,
• Or both!