455 Golden Gate Ave., 10th FloorSan Francisco, CA 94102Phone (415) 403-4920FAX (415) 703-5477

STATE OF CALIFORNIADEPARTMENT OF INDUSTRIAL

RELATIONSDMSION OFAPPRENTICESHlP

STANDARDSAUDITREPORT

ForI11temationalAssociation ofBridge,

StrUctural and Ornamental and ReinforcingIron Workers Local 416 Joint

Apprenticeship Training Committee,File No. 08885

The Division ofApprenticeshipStandards creates opportunitiesfOrCalifOrnians to gain employable lifetime skills andprovidesemployers with ahighlyskilledandexperiencedworliforcewhilestrengthening CalifOrniaseconomy.

CONTENTS

Summary 3

Findings and Recommendations 3

Audit Highlights/Introduction/Background 4

Scope/Focus/Methodology 6

Audit Results and Recommendations 7

Comments from Program Sponsor 17

Corrections and Timeline 17

Remarks 17

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SUMMARY

The Division of Apprenticeship Standards (DAS) presents its audit report concerningThe International Association of Bridge, Structural and Ornamental and ReinforcingIron Workers 416 Joint Apprenticeship Training Committee (JATC) program; DAS filenumber 08885, (hereafter "program").The program's standards were approved onOctober 1, 1996, and completely revised on May 24, 2005. The program hassubmitted several revisions to its approved standards, the most recent beingapproved on December 19,2007. The program was randomly selected by DAS foraudit compliance. The audit was performed from July 28, 2008, through August 1,2008, and was conducted pursuant to California Labor Code §3073.1.

As noted in the detailed report which follows, the auditor found that the program isdoing an excellent job of training apprentices and keeping them on schedule and onlysome minor changes are necessary to bring the program into compliance with theirapproved standards and legal requirements.

FINDINGS AND RECOMMENDATIONS

The program is doing an excellent job of training apprentices and keeping them onschedule with wage increases and Related Supplemental Instruction (RSI). Thetraining coordinator, instructors, and facility clerical staff keep accurate records onclass attendance and completion of RSI. Accurate records are in place to notifyemployers of apprentice upgrades and rate increases. The auditor found that someadditional documentation and verification is necessary in order to reconcile on-the ­job training (OJT) hours with programs approved work processes.

Detailed findings and recommendations are included in this report. The coordinatorwas presented with a summary of the findings and a recommendation was presentedto assist him in preparing the appropriate corrective action. The DAS will visit theprogram in the future to verify compliance with the recommendations. These DASaudit procedures allow the program to respond to the recommendations and theirresponse will become part of this formal report.

During the audit examination Training Coordinator, Paul E Martinez~ commented thathe and his staff are committed to the success and improvement of the program andwelcomed any recommendations and/or suggestions that would help the programachieve its goal of graduating skilled journeymen. He also stated that TheInternational Association of Bridge, Structural and Ornamental and Reinforcing IronWorkers 416 Joint Apprenticeship Training Committee (JATC) is committed tohelping apprentices reach their goal of becoming skilled journeyman and workingsafely in the trade.

The program was receptive to the recommendations made by the auditor andimmediately implemented some record keeping changes to bring the program intocompliance with their approved standards and legal requirements.

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AUDIT HIGHLIGHTS.....

Our review of The InternationalAssociation of Bridge, Structuraland Ornamental and ReinforcingIron Workers 416 JointApprenticeship TrainingCommittee (JATC) program;Division of ApprenticeshipStandards (DAS) file number08885, (hereafter "program")found that:

• Audit review found that theprogram has submittedseveral revisions to itsapproved standards, themost recent being approvedDecember 19,2007.TheDAS approved program'scomplete revision to itsstandards on May 24, 2005.

• The program requires allapprentices to sign andconfirm that they understandthe program's Rules andRegulations. All of theapprentice files examinedcontained signed copies ofthe rules and regUlationsreceipt.

• The program files containedconsistent verifiable OJTwork hours but did notcontain a verifiable tally ofthe various work processes.

• The apprentice is required tocomplete an ApprenticeQuarterly Work and TrainingRecord (program's version ofDAS Form 103) to track workprocesses and OJT workhours.

• Files examined containedcopies of ApprenticeQuarterly Work and TrainingRecord signed by theapprentice but not signed bythe foreman and/orsupervisor.

Continued

INTRODUCTION/BACKGROUND

The audit began on July 28, 2008, and was completedon August 1, 2008 The auditor met with keyadministrative personnel, examined records, observedadministrative activities, conducted a walk-through ofthe training facility, observed a classroom session, andvisited two job sites in connection with the audit.

The International Association of Bridge, Structural andOrnamental and Reinforcing Iron Workers 416 JointApprenticeship Training Committee (JATC) programoperates as a Labor/Management Cooperative and theprincipal partners in the cooperative effort are WesternSteel Council, Inc, and Local Union No. 416International Association of Bridge, Structural,Ornamental, and Reinforcing Ironworkers. Theprogram has an Apprentice Trust Fund. The program'sfunding mechanism comes from employercontributions, Related Supplemental Instructional (RSI)funds (Montoya Funds) and state prevailing wagetraining fund contributions.

The daily operations, management and administrativefunctions are run by four primary staff, Paul Martinez,Training Coordinator, Yvonne Garcia, Office Manager,and Jessica Lozano and Monica Menal ClericalWorkers. The program employs 3 full time certifiedinstructors and uses retired, qualified ironworkers assubstitute instructors as needed. The program office islocated at 5555 Fresca Drive La Palma CA 90623. TheLa Palma training facility also serves as the program'smain office and daily place of business. The programmaintains all indentured apprentice files at thatlocation. The program employs three full time clericalstaff workers to maintain the apprentice files.

The International Association of Bridge, Structural andOrnamental and Reinforcing Iron Workers is a 48­month program. Apprentices meeting the requiredadvancement criteria progress through 8 upgradesteps until completion. Training consists of 664 hoursof related supplementary instruction (RSI) and 5600hours of accumulated on the job training (OJT).

Employers are approved to train when they havecompleted an Agreement to Train Apprentices, DAS-7form. The program indicated that they dispatch to bothunion signatory employers and non-union employerswho agree to abide by the program's standards, rules,regulations and policies.

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The apprenticeship program provides a trainingprogram for the following occupation:

• Work processes areconsistent with program'sapproved apprenticeshipstandards but are not beingproperly recorded.

Name of Term ofoccupation occupationReinforcing Ironworker 48 months

Number ofapprentices420

• Job site review found thatthe apprentices interviewedare completing theApprentice Quarterly Workand Training Record. Allstated that they turned it in tothe program when theyattend school or when it wascompleted.

• Apprentice files examinedcontained copies of schoolabsences, evaluations,progress reports and finaltest scores.

• The program has completedand submitted the annuallyrequired Self-AssessmentReview and ProgramImprovement Plan to DAS ina timely manner.

• The program committeemeeting minutes includeformalized motions toapprove indentures,upgrades, prior credit,cancellations, completions,evaluations and discipline ofapprentices.

The Related and Supplemental Instruction is providedby the program's training center which is located atthe same site as the program operations. Eachapprentice enrolled receives an orientation packetthat includes the rules and regulations, an explanationof the program's standards, an Apprentice QuarterlyWork and Training Record (program's version of DASForm 103) and a class schedule.

The program's Local Education Agency (LEA)is Cerritos Community College located at11110 Alondra Boulevard, Norwalk CA90650. Maggie Cordero is the LEArepresentative for the program.

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SCOPE AND FOCUS

The principal objectives of the audit are to ensure the program is complying with theirstandards, that all on-the-job training is performed by a journeyman, that all related andsupplemental instruction required by the apprenticeship standards is being provided, thatall work processes in the apprenticeship standards are being covered, and that graduateshave completed the apprenticeship program's requirements.

The audit focused on reviewing records and activities that tend to support andsubstantiate the program's efforts, practices, systems and capabilities to provide anddeliver the on-the-job training and related instruction. The program's policies andprocedures were reviewed to determine if they support the program's approvedstandards.

METHODOLOGY

After completing an initial review of the program's standards and records on file with theDAS, an audit plan was established with the following steps:

1. Notified the program 14 days in advance of our intent to audit.

2. Prepare an entrance interview

3. Organization of all working papers to conduct the interview

4. Confirm the location where records are maintained

5. Conduct a random review of apprentice files

6. Set the time and date of the meeting

7. Schedule inspection of the training facility and job sites

8. Request and review copies of the committee meeting minutes for the last 12months.

All steps listed above were accomplished and include interviews with primary staff,apprentices and job site supervisors.

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AUDIT RESULTS

1. STANDARDS

The objective is to determine whether the programs are submittingperiodic revisions to their standards and if standards are reasonablycurrent. "Standards" are a written document containing all terms andconditions for the qualification, recruitment, selection, employment andtraining, working conditions, wages, employee benefits and othercompensation for apprentices. It may also include other provisions andstatements. All apprenticeship programs are required to submit theirapprenticeship standards to the DAS Chief for approval. The CaliforniaCode of Regulations states the program must submit revisions to itsstandards when necessary.

(a) Findings

(1) Our audit review found that DAS approved program's completerevision of its standards on May 24, 2005.

(2) Program is submitting Revision of Approved Standards in a timelymanner for DAS approval.

(b) Recommendations

(1) Continue to review and update standards as needed or wheneverany changes are made to the apprenticeship program and report thisinformation to the DAS Apprenticeship Consultant.

Article IV (5) of the program's standards, Section 205 {fl, 212 (a){§l ill (c)I2l {JJl of the CaliforniaCode of Regulations states that the program sponsor must submit revisions to its standards whennecessary.

2. RULES AND REGULATIONS

The objective is to determine if the programs have adequate rules andregulations, are implementing them as required, and provide a copy tothe apprentices. The rules and regulations can be defined as anorientation or workshop session that explains the apprenticeshipprogram standards and the operation of the apprenticeship program. Itincludes information on what is expected by both the program and theapprentice.

The rules and regulations for this program were adopted and contain apolicy statement showing responsibilities of the apprentice and thecommittee. Apprentices are cited for failure to follow the rules andregulations. A letter of citation is mailed to the apprentice to appearbefore the committee and failure to appear is reason to recommendcancellation from the program for failure to comply with a committeedirective. Additionally, the rules and regulations state that eachapprentice will be notified in writing of the date(s) that she/he is to attendRSI classroom training.

Applicants must be at least 18 years of age and must be able tophysically perform the work of the craft. A drug test is required prior toindenture. When the apprentice is approved by the program to enter the

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training he/she is given a copy of the rules and regulations andscheduled for eight Saturdays of orientation classes. Failure to attend allclass meetings will result in a work suspension or termination from theprogram. The apprentice must sign the document indicating they havereceived, read and understood the rules and regulations.

(a) Findings

(1) This review found that the apprentice files contained signedcopies/receipts to acknowledge the apprentice received, read, andunderstood the rules and regulations.

(2) The rules and regulations are reviewed by the Committee andupdated when needed. The Committee applies the rules andregulations in a fair and consistent manner. Actions taken by theCommittee are reflected in the meeting minutes and apprenticeshipfiles.

(b) Recommendations

(1) Continue enforcing rules and regulations in a fair and consistentmanner.

Article VI (2) of the program's standards, Section 3071,3073, and Section 212 (a) (6) (7), (c) (2) (3) (B), (14)of the Califomia Code ofRegulations states that the program must establish rules and regulations thatgovem the program.

3. ACTIVE APPRENTICES AND CANCELLATIONS

The review of this item is to determine if the program is monitoringapprentices as they enter and proceed through the program. It is also todetermine if the program is maintaining accurate records on both theactive and cancelled apprentices. The program should have the ability toprovide evidence of procedures used for periodic reviews and evaluationof the apprentice's progress in job performance and related instructionand maintenance of appropriate progress records. In addition, theprogram should have a process in place to notify the DAS when anapprentice leaves the program.

(a) Findings

(1) The program's numbers of registered indentured apprentices (420) werecorrect and consistent with the number of apprentices registered with theDAS.

(b) Recommendations

(1) Continue to keep the DAS informed of indentures, cancellations andcompletions in a timely manner. All changes affecting the status ofthe apprentices in the program must be submitted to the DAS.

Section 205 (a)(1)(2) (i), 212 (a){§l m(B), (b)(9), (c)(2)(10) 224 of the California Code of Regulationsstates that the program sponsor must maintain accurate apprenticeship records and submit changes,updates and revisions ofan apprentice's status when necessary.

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4. ON -THE JOB TRAINING (OJT) PROGRESS RECORDS,ADVANCEMENTS AND EVALUATIONS

Our review is to determine if apprentices are progressing on schedule,that the program is maintaining adequate OJT records, receiving periodicevaluations and if the program has adequate records and a system inplace to ensure that apprentices are covering all the work processes.

The program uses the following items to track apprentices' schedules:OJT records, periodic evaluations and satisfactory completion of RSIclasses. Apprentices are advanced twice a year, March and September,upon completion of RSI and OJT hours with the JATC approval.

• Satisfactory completion of required RSI classroom hours. Standardsstate, apprentices shall satisfactorily complete prescribed courses ofRSI, which will be no less than 160 per year. Program requires 166per year.

• Accumulation of 700 OJT hours from an approved contractor verifiedby the Field Ironworkers Trust Administration and/or original checkstub from an approved contractor. Note: In July 2008, programsubmitted a Revision of Approved Standards changing upgradesbased on a minimum of 600 OJT hours and successful completion ofRSI. Program is waiting on DAS approval.

• Satisfactory passing (60% or higher) on each unit exam, inconjunction with satisfactory progress/evaluation reports frominstructor.

Program provides the apprentice with a Quarterly Work and TrainingRecord (program's version of DAS Form 103) to document and recordOJT hours and work processes. The work and training record contains adaily and monthly log to record hours worked in the various workprocesses. The work and training record has a place for the supervisor'ssignature and a list of the various work processes.The apprentice isrequired to turn-in his work and training report every quarter or whenreporting to school. If apprentice is current with RSI hours and has therequired OJT hours he/she is advanced to the next level of training andreceives a wage increase.

Audit files reviewed had the apprentice quarterly work and trainingreports but they were not signed by a supervisor/foreman. Reviewedfiles did contain a total of OJT hours, completed RSI classes, test scores,attendance records, and evaluation and progress reports. Files did notcontain a current breakdown or tracking system of the approved workprocesses.

(a) Findings

(1) The program is not utilizing the quarterly work and training report orany other type of tracking record form/process, and is not verifyingthe various work processes.

(2) The quarterly work and training report is not signed by a supervisorand/or foreman.

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(b) Recommendations

(1) Develop a process to track and/or identify apprentice OJT workprocess hours. Keep a copy of this information in each apprenticefile- due within 60 days.

Note: Program Training Coordinator, Paul Martinez took immediateaction and implemented some record keeping changes to bring theprogram into compliance with their approved standards.

(2) Have all forms verifying work processes signed by the apprenticeand the supervisor/forman - due within 60 days.

(3) Keep the complete and signed quarterly work and training report ineach apprentice file. Additionally develop a consistent process totrack and/or identify apprentices various work process and citeapprentices who have not submitted timely OJT hours - due within60 days.

(4) Provide training and instruction to apprentices and employers onhow to properly record OJT hours and work processes- due within 60days.

Section XVII of the program's standards, and Section 3073.1,3076, 3078(e) of the LaborCode, and Sections 208, 210, 212(a) (4) (5) (7) (8), (b) (9), (c) (2) (6) (8) (9) (16) (18), ofthe California Code of Regulations. The program must offer training and supervision in allthe work processes defined in its standards and has a system to ensure that apprenticescover all the work processes. The program must have a system of documenting andmaintaining records that will assist in the review and evaluation of each apprentice'sprogress in job performance. The program must have a procedure for recording andmaintaining accurate records, and a procedure for periodic review and evaluation ofprogress.

5. RELATED AND SUPPLEMENTAL INSTRUCTION (RSI)

The objective of our examination was to determine if apprentices areprogressing on schedule, attending classes, covering the entire course ofstudy, and to ensure the programs are maintaining accurate records withadequate systems in place to provide training.

The program's Related and Supplemental Instruction is approved by aLocal Education Agency (LEA). The LEA is Cerritos Community Collegelocated at 11110 Alondra Boulevard, Norwalk CA 90650. MaggieCordero is the LEA representative for the program.

The course outlines as written by the program have been reviewed andapproved by the LEA.

The apprentices are required to attend assigned classes immediately upon beingindentured in the program. Classes begin with eight Saturdays of Orientation asan introduction to the trade (64) hours. The apprentice is then scheduled tocomplete 15 (40 hour) core classes over the course of their apprenticeship. Theclasses are offered under a semester system and, after completion of theSaturday classes, the classes are structured in a Monday-Friday format. Theapprentices are not compensated for RSI, but can apply for unemploymentbenefits.

An apprentice that fails to attend the first assigned class meeting of eachsemester will be removed from the sign-in roster and cited to appear before the

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JATC at their next regularly scheduled meeting. Each apprentice will be requiredto attend each assigned class for the full class session. After a single absence,the apprentice will be notified that he/she missed class hours in excess of thoserequired to fulfill class requirements, and will be referred to the JATC. Uponreview by the JATC the apprentice will either:

• Receive a one day job suspension and directed to appear for a make-upclass date.

• Reassigned to the same classes in the next semester.• Cancelled from the Apprenticeship Program.

Three tardies (arrival up to fifteen minutes after the class begins) shall beequivalent to one absence. Each additional tardy shall be equivalent to oneabsence. Apprentices arriving over fifteen minutes late will be considered absentfrom the class. Leaving class prior to dismissal shall be equivalent to oneabsence. Upon missing the second class meeting the apprentice will be cited toappear before the JATC at which time appropriate action will be taken. Schoolauthorities, who include the Instructors, may suspend an apprentice from classand/or schooL At which time a referral will be submitted to the JATC forappropriate action for the apprentices who violate school rules and/or theauthority of the instructor.

Every apprentice must bring tools and study materials to class before signing inon the "class sign-in sheet". The rules and regulations state that the apprenticeshall first request permission, in writing, from the Committee/Coordinator to beexcused from attending classes, indicating the documented reason for such arequest.

(a) Findings

(1) The records of attendance, test scores, progress evaluations, andclassroom hours for the apprentices are recorded on the program'scomputer data base. A record of this information is also kept in theapprentice file.

(2) The apprentice files examined contain a consistent record of allabsences related to school attendance, test scores, copies ofadvancement letters to employer and apprentice, and anydisciplinary actions.

(b) Recommendation

(1) Coordinator and Instructors should continue to provide updates tothe program and the apprentices on how they are progressing intheir required educational courses. Review curriculum and developnew courses to cover additional needs when needed.

Section XVI of the program's standards, Section 3073.2, 3078(d), of the California Labor Code, andSection 205(e)(h), 212(a)(3)(6)(7) (c)(13)(14) of the California Code of Regulations states that it isrecommended that the program provide a minimum of 144 hours per year ofsupplemental instructionfor each year of apprenticeship and adequate arrangements for related and supplemental instruction,and have the ability and commitment to train apprentices with current industry standard criteria.

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6. TRAINING CENTER

The objective is to ensure the program has adequate facilities, tools,materials and equipment to train apprentices, and to determine if thefacilities are utilized and adequate for training.

The program employs 3 full time instructors, and all full time instructorshave teaching credentials. During the visit, classes were in session andthe auditor was able to observe a classroom session. The instructorsconduct classes on a weekly schedule at the training center. The auditorspoke with several of the instructors and toured the La Palma trainingfacility. The training center is located at the same location as theprogram. The training center is a 29,500 square foot building that sits on2.77 acres. It consists of five classrooms and one shop lab utilized fordemonstrations and "hands-on" working projects. The instruction is donewith good health and safety practices in mind.

(a) Findings

(1) Our inspection of the training facility found it to be sufficient to trainapprentices.

(b) Recommendation

(1) The program should continue current practices and insure plans forgrowth are based upon the current successful model.

Section 3074 of the Califomia Labor Code-Section 212(a) (3) (4) (8), (c) (13) (12), 212.3 of theCalifomia Code ofRegulations states that the program sponsor must have adequate arrangementsfor related and supplemental instruction.

7. MECHANISM TO KEEP APPRENTICES REASONABLYEMPLOYED

Our objective is to determine if apprentices are kept reasonablyemployed, to ensure the program has adequate systems in place torotate apprentices so they cover all work processes, and to provideapprentices with continuing employment in the event of a layoff.

The review found the program has an established system to keepapprentices reasonably employed and to provide them with continuingemployment in the event of a layoff. If an apprentice becomesunemployed they should immediately register on the out-of-work list attheir local union. In addition apprentices are given a list of employersand are encouraged to solicit employment with an employer within any ofthe twelve counties covered by these Standards.

Unemployed apprentices attending RSI classroom training may beeligible for unemployment insurance benefits. Unemployment insurancetelephone numbers are given to those apprentices meeting EDD criteria.

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(a) Findings

(1) The review found the program has an established system to keepapprentices reasonably employed and to provide them withcontinuing employment in the event of a layoff.

(2) The records found the referral/dispatch system keeps theapprentices employed within their industry. They are also referred toother employers, giving the apprentices an opportunity to train in allwork processes.

(b) Recommendation

(1) The program should continue the system they have in place andencourage additional employer involvement.

(2) The program should continue to refer apprentices to other employersand encourage the apprentices to solicit work on their own.

Section 3080 of the Labor Code, and Section 212 (b) (7) (9), (c) (16) (18) ofthe California Code ofRegulations. The program(s) must have a mechanism to keep apprentices reasonably employed andmaintain accurate documentation Section 3080 of the Labor Code, and Section 212 (b) (7) (9), (c)(16) (18) of the Califomia Code ofRegulations.

8. JOB SITE VISIT

A review of the job site offers an opportunity to view a job in progress,observe the work that is being done, and allows us to discuss theoperation of the program with the apprentice. It enables direct contactwith the apprentice to determine the following:

• If the apprentice is performing the various tasks listed within the workprocesses of their trade.

• If advancements are made on schedule.

• If the apprentice is receiving the correct pay and benefits.

• If the apprentice is kept employed on a reasonably continuous basis.

• If the program's mechanism to keep apprentices reasonablyemployed is adequate.

The program suggested five job site locations to visit. Telephone callswere made to arrange a review of the job sites and contact was madewith two locations.

The auditor visited a job site located in Irvine California called the ParkSpectrum and found two apprentice working under the supervision anddirection of journeymen and employed at tasks defined within the workprocesses of the program standards.

The auditor also visited the East Los Angeles High School # 2 job sitelocated in East Los Angeles, California and found three apprenticesworking under the supervision and direction of journeymen andemployed at tasks defined within the work processes of the programstandards.

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Interviews were conducted with all of the apprentices. The auditor foundthat the apprentices had the equipment, materials and tools of the tradesufficient to train apprentices. Each apprentice receives proper pay andbenefits and attends OJT classroom training. The interviews confirmedapprentices are advanced on schedule. The apprentices interviewedstated that they write in the total hours of OJT training on their apprenticework and training record broken into the various work processes. Oneapprentice had a copy of his work and training record in his possession.The other apprentices interviewed did not have their work and trainingrecord but stated that they had it in their car or at home. The apprenticesverified that work and training record sheet is not signed by the job sitesupervisor. All apprentices interviewed stated they had to turn in thework and training record sheet to the program every quarter or whenthey attended school.

The interview with the supervisors confirmed there is a proper ratio ofjourneyman to apprentice and adequate supervision. All the apprenticesinterviewed stated they were very satisfied with the program and allconfirmed that they were being properly trained. Apprentices also statedthat they were very pleased with the program's class instructors and thatwhenever they had a problem understanding the course work theinstructors would work with them individually until they understood.

(a) Findings

(1) Supervisor/foreman are not signing or verifying the work processeson the work and training record sheets.

(2) The auditor found that the apprentices were filling out the work andtraining record sheet and submitting it to the program on a quarterlybasis.

(c) Recommendations

(1) The program should provide training and instruction to theapprentices and the employers/supervisors on how to properlyrecord OJT hours and work processes. Program should stress theimportance of having the foreman/supervisor sign the work andtraining records sheets thereby verifying the work processes- duewithin 60 days.

(2) The program should continue to ensure apprentices are correctlyrecording work process and OJT hours and are tracking hours withinthe individual work processes.

(3) The program should continue to ensure each apprentice turns intheir record sheet to the program quarterly and continue to keep acomplete and signed record sheet in each apprentice file.

Section 208, 212(a) (1) (2) (4), (b) (4) (5) (6), (c) (6) (13) (14) of the California Code ofRegulations states that all on-the-job training will be performed by journeymen, that allrelated and supplemental instruction required by the apprenticeship standards will beprovided, that all work processes ill the apprenticeship standards are being covered, andthat graduates have completed the apprenticeship program's requirements.

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9. SELF-ASSESSMENT REVIEW AND PROGRAMIMPROVEMENT PLAN

The objective is to determine if the program has submitted the annualSelf-Assessment Review and Program Improvement Plan. The CaliforniaCode of Regulations Title 8, Section 212.3 requires programs to performan annual self-evaluation and to create an improvement plan. The DASnow requires that each program submit a copy of their Annual Self­Assessment Review and Program Improvement Plan to theirapprenticeship consultant by December 1 of each year.

(a) Findings

(1) The required annual Self-Assessment Review and ProgramImprovement Plan for 2007, was submitted on December 5,2007.

(b) Recommendations

(1) Continue to submit the Self-Assessment Review and ProgramImprovement Plan in a timely manner.

(2) Use the Self-Assessment and Program Improvement Plan as a toolfor setting goals for your program and adapt the listed changesduring the next 12 month period.

Section 212 (a) (6) (7), (c) (2) (11), 212.3 of the California Code of Regulations states that theprogram sponsor must submit annually a Self-Assessment Review and Program Improvement Plan tothe DAS.

10.COMMITTEE MEETINGS AND MINUTES OF MEETING

Joint apprenticeship committees have equal representation from laborand from management. Each committee also includes a consultantrepresenting the Division of Apprenticeship Standards or the Bureau ofApprenticeship and Training, U.S. Department of Labor. There is also anadvisor from the local public school district, and such other advisors andthe apprenticeship consultant act without vote. This committee isresponsible for administering the Standards for this program. In carryingout its functions, the committee has certain authority under the law. Theactions, therefore, must be in accordance with approved apprenticeshipstandards and should be recorded in the minutes.

The objective is to determine if the apprenticeship committee is meetingon a regular basis, documenting actions, discussing and reviewingapprenticeship records, and making appropriate assessments andevaluations.

The committee provided the program committee meeting minutes for thepast year. The committee meetings are held monthly. The meetings areconducted in the La Palma office. An advance notice is sent out to allmembers and any guests of the committee.

(a) Findings

(1) The program committee is a Labor/Management Co-Operative andhas four labor representatives and four management

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representatives. The committee also includes one advisorapprenticeship coordinator and one advisor local education agencyrepresentative. All advisors act without vote. All disciplinary actionsare reviewed by the committee.

(2) Our review of the committee minutes for the last 12 months showedthat the committee had a record of disciplinary actions. Thecommittee minutes were sufficient in form and content.

(b) Recommendations

(1) Continue to hold regular meetings and keep accurate committeeminutes and records.

(2) Continue to ensure DAS apprenticeship consultant is advised ofcommittee meetings well in advance and the consultant willendeavor to participate in meetings when possible.

Section 3076, 3080(b), 3078(d)(f), 3079, 3093(k), of the California Labor Code, and Section 213, 218,212(7), 208(5), 205(e)(f)(g)(i), 212(c)(1)(6) (9), 224 of the California Code of Regulations states thatthe program sponsor must maintain adequate documentation and records.

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COMMENTS FROM PROGRAM SPONSOR

Comments, if submitted by the program sponsor during the 14-day review andcomment period, will be included with this report to the Chief of DAS andultimately to the California Apprenticeship Council.

CORRECTIONS AND TIMELINE

The audit findings and recommendations are set forth in this report. The programhas 14 days from the receipt of this report to review and submit comments on thereport. Within 10 days following the receipt of comments or the completion of thecomment period, a final report will be submitted by the Chief of DAS to theCalifornia Apprenticeship Council.

The final report will detail the findings with recommendations for remedialactions. The program must remedy all deficiencies and be in full compliance withits apprenticeship standards. The program must notify the DAS in writing whendeficiencies have been remedied. A DAS representative will schedule anappointment to review the completion of the remedial actions. Failure to complymay be grounds for withdrawing state approval of the apprenticeship program.

11.REMARKS

The results of this audit do not modify, replace or negate other duties andrequirements or any previous notices you may have received regarding thefulfilling of your obligations prior to or after the audit period. In addition, lawchanges or new rulings might result in different findings in future audits.

Respectfully submitted by,

Salvador Trujillo

Apprenticeship Consultant, AuditorDAS, Los Angeles District Office

Date

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Rachel Freeman

From:Sent:To:Cc:SUbject:

Salvador TrujilloWednesday, September 03, 2008 10:05 AMRachel FreemanByron Cummins; Amelia MezaFile No. 08885 Ironworkers

On September 3, 2008, I spoke with Paul Martinez (coordinator for the Ironworkers apprenticeship program)and asked him if he had submitted a response to the audit report. He said that he was very pleased with theaudit and did not plan on rebutting any of the recommendations and therefore did not find it necessary toprepare a response. Paul also said that he was in the process of completing all the recommendations noted inthe audit report. I will mail the audit report to the DAS Fresno District office today.

St'vtvt'v~C1rrrujiUC1Apprenticeship Counsultant, Audit UnitDepartment of Industrial RelationsDivision of Apprenticeship StandardsOffice: 213~576~7750

Direct: 619~929~5827

Fax: 213~576~7758

E~Mail: STnriillo@c1ir.ca.g~

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