EPPC Scholar Submits Comment Opposing DOL’s Equity-Focused National Apprenticeship System Proposed Rule 


Published March 18, 2024

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On March 18, 2024, EPPC scholar Natalie Dodson submitted a public comment opposing a proposed rule by the U.S. Department of Labor (DOL) that would promote the Biden Administration’s diversity, equity, inclusion, and accessibility goals in the National Apprenticeship System. 

DOL claimed the regulations were meant to “increase[e] clarity” and “ensur[e] equitable apprenticeship opportunities for underserved communities.” Yet, as Dodson argued in the comment: 

In an environment where local and state governments are already dealing with apprenticeship labor shortages, as well as a shortage of registered national apprenticeship program sponsors, the Department’s proposed requirements for nondiscrimination, training, and education will deter apprentices and program sponsor applicants rather than encourage participation in the apprenticeship system. The proposed rule also raises serious religious freedom concerns, which the Department fails to address.  

Additionally, Dodson pointed out that DOL failed to mention “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” in the proposed rule. She encouraged “DOL to acknowledge and address the impact of all relevant federal laws protecting religious exercise.” 

Dodson urged DOL to withdraw its proposed rule. 


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, health care rights of conscience, abortion, and nondiscrimination in EPPC’s HHS Accountability Project.

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