Published July 18, 2024
On Thursday, July 18, 2024, EPPC scholar Natalie Dodson met with government officials in the Executive Office of the President (EOP) to oppose a Department of Labor (DOL) rule detailing national apprenticeship system “enhancements.”
As Dodson explained, “I support the Department’s goal of ‘improv[ing] the quality of registered apprenticeship programs,’ however, this rule would have the opposite effect.”
During the meeting, Dodson raised several points, including that the DOL failed to demonstrate a need for its rule; the rule is unclear and will create uncertainty and confusion; the rule overstates its benefits and fails to count its costs; and it does not adequately protect religious liberty.
With regard to religious liberty concerns, Dodson stated “the proposed rule failed to cite the First Amendment or consider other federal laws protecting faith-based organizations and religious employers from making employment decisions based on religion, such as Title VII and the Religious Freedom Restoration Act.”
The rule charges DOL with promoting “diversity, equity, inclusion, and accessibility” and obliges program sponsors and participating employers to “promote and maintain a safe environment that is free from violence, harassment, intimidation, and retaliation” without defining these terms or clarifying what they require with regards to “historically marginalized communities” such as “lesbian, gay, bisexual, transgender, queer, gender nonconforming, and nonbinary persons.”
Dodson advocates for religious organizations by urging that “in cases where faith-based, religious organizations or religious employers seek to sponsor a program, I urge OIRA to consider the impact of all relevant federal laws protecting religious exercise.”
Dodson concluded with several suggestions and recommendations to improve the rule.
A written version of the comments submitted to EOP’s Office of Information and Regulatory Affairs is available here (PDF).
Natalie Dodson is a Policy Analyst at the Ethics and Public Policy Center, where she works on a range of initiatives focusing on sexuality, gender ideology, religious liberty, healthcare rights of conscience, abortion, and nondiscrimination in EPPC’s Administrative State Accountability Project (ASAP).
