Encouraging Self-Identification and Measuring Against the 7% Utilization Goal

7%The 2016 EEO Rule adds disability to the bases protected by the nondiscrimination requirement, and it adds disability as an element of sponsors’ affirmative action programs. Rather than each program conducting an availability analysis specific to its labor market, the EEO Rule establishes a single, national utilization goal that 7% of programs’ apprentices be people with disabilities.

The Registered Apprenticeship Partners Information Data Systems (RAPIDS) is the administrative data system for most RAPs in the US. RAPIDS includes data on the prevalence of registered apprentices with disabilities. In 2019, only 0.39% of registered apprentices in the RAPIDS system reported having a disability, according to the Urban Institute’s report, “Inclusive Apprenticeship A Summary of What We Know about Apprentices with Disabilities”.

This 7% goal is based upon available labor market demographic data and is consistent with OFCCP’s revised Section 503 regulations that, among other things, established a nationwide 7% goal for the utilization of qualified individuals with disabilities by federal contractors.

There is a two-step process for sponsors to determine the current disability makeup of their apprenticeship workforce to promote the inclusion of qualified individuals with disabilities in their programs.

  1. Self-Identification: To provide sponsors with necessary information on applicants’ and apprentices’ disability status, RAP sponsors are required to invite their apprentices and applicants to voluntarily indicate (self-identify) whether or not they are a person with a disability. View our detailed tips on encouraging self disclosure.
  2. Workforce Analysis: Sponsors must analyze the representation of people with disabilities within their apprenticeship program. They should then compare the proportion of current apprentices with disabilities, by major occupational group, to the 7% utilization goal. If the percentage of people with disabilities is less than 7%, the program must review the personnel procedures and outreach and recruitment efforts to determine if impediments to equal opportunity for people with disabilities exist. Registration agency staff will assist the sponsor with this review.

How to Invite Apprentices and Applicants to Self-identify as a Person with a Disability

  • Sponsors must use the standard Voluntary Disability Disclosure Form to invite apprentices and applicants to indicate whether or not they have a disability at multiple points in the apprenticeship process. They must keep the information on these forms entirely confidential. Sponsors must solicit responses to the disclosure form at these times:
    • Applicants for apprenticeship are to be invited to self-identify at the time of application.
    • Applicants for apprenticeship are to be invited to self-identify once hired into the program, but before they begin their apprenticeship.
    • Once they begin their apprenticeship, apprentices are to be invited to update the form annually, as their disability status may change over time.

While the choice to self-identify is completely up to each person, sponsors can create an environment in which apprentices and applicants feel more comfortable self-identifying by taking steps such as:

  • Emphasizing that providing information is voluntary and will only be used to measure progress toward greater inclusion of people with disabilities.
  • Inviting apprentices with disabilities to assist in the program’s recruitment of new apprentices.
  • Featuring apprentices with disabilities prominently in the program’s recruitment materials.

Check out PIA’s Encourage Disability Disclosure page to learn more.

Frequently Asked Questions about the 7% goal

Is this a quota?

This goal is not a quota. It does not create a “set-aside” for people with disabilities and cannot be used to supersede standard requirements for program eligibility. Sponsors must not base employment decisions on an candidate’s disability status, and sponsors are not in violation of the regulations merely for falling short of the goal. The goal serves as a benchmark against which sponsors measure their inclusion of people with disabilities in their apprenticeships. Sponsors that do not meet the goal are required to examine if impediments to equal opportunity exist, and if so, to correct those impediments.

Does this goal apply to all apprenticeship programs?

The 7% goal applies to apprenticeship sponsors that are required to maintain affirmative action programs (programs with 5 or more apprentices). However, certain sponsors of RAPS are exempt (read more about exemption).

Review this tip sheet from DOL to learn more about the 7% utilization goal for more information.