2. Progress delays due to cumbersome BAT field regulations and the lack of prior established guidelines governing the administration of and regional authority pertaining to national prime contracts

Considerable time and effort was spent developing the interest and cooperation of the individual industrial laundries. This phase of the Project was considered highly successful as indicated by the number of laundries agreeing to operate training programs. In many cases interest is now waning because the launderers are beginning to feel that this is not the Institute of Industrial Launderers and National Bureau of Apprenticeship Training projects that they were informed it would be.

These launderers were under the impression that the project had already been approved by the authority of the prime contract and are wondering why so much local level approval, regulations and delays affecting the progress of the program are necessary.

As an example: On October 6, 1965, an industrial laundry in Arlington, Virginia, agreed to start a training program to train 5 trainees starting by filling 2 current openings for a towel counter-folder and a janitor, with the remaining three trainee positions to be determined as openings occurred. Before the subcontract could be written, the Project staff had to reproduce the necessary forms because none were available due to recent form changes at the national level.

A meeting was set up with a representative from BAT Region III-IV to determine how Region III-IV projects would be approved and by whom. A workable solution was arrived at, subject to approval, which would allow BAT field representatives to approve subcontracts on the spot and send necessary data by a report form to involved BAT regional offices. Such a report form was developed, but never used because of the varying field procedures and requirements at the local level. The subcontract was submitted for approval and it was determined that the job training arrangements had to be listed in advance for each of the proposed 5 trainees. The contract was returned to the industrial launderer and as a result the number of trainees was reduced to 2 as it was impossible to determine what future positions would be open in which to train the remaining 3 trainees. On November 3 the revised subcontract was sent to the Chambersburg BAT office for approval. As of the first of the year, two months will have elapsed and no word has been received regarding the above-mentioned subcontract.

Result: The industrial launderer has since hired "normal" persons to fill the jobs. The DVR counselor who hurriedly located and screened appropriate trainees is none too happy about it.

Assuming the subcontract will be approved as submitted, the positions for training listed thereon have been filled and that the next opening may not be in the job areas as listed; this means that the contract may have to be rewritten and reapproved with the possibility of the same thing happening over again. This points out the need to write the subcontract authorizing training in any of the authorized positions. Subcontracts submitted for approval for Baltimore projects have resulted in very much the same situation.

3. The project staff becoming extensions of regional and local BAT and BES staff

Every local project must be screened, approved and administered according to the various standard procedures as well as those peculiar to each BAT and BES local office. This makes it necessary for the Project staff to meet with and/or have approved by writing all anticipated projects with the regional office and each involved state or local BAT and BES office before the program can be implemented. The amount of time and work involved is, therefore, tripled. The Project staff has no objections to the regional or state offices approving the project and appreciates the necessity of these offices being kept informed regarding OJT programs operating within their jurisdiction, but there are reservations regarding the method by which this must be done. It would seem that a blanket approval by the regional director of each region would be sufficient as long as the necessary supportive information and copies of contracts, etc., are sent monthly to the director. In effect the Project staff is becoming extensions of the staff of each regional and local BAT-BES office. Since all projects must be approved by regional BAT staff, the Project staff is left with little or no authority to carry out the responsibilities placed on them by the prime

contract.

The result becomes one wherein the regional, state and local personnel are establishing procedures and policy for the national office rather than the au

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thority of the national office establishing procedures for the regional offices to follow in dealing with national prime contracts.

4. Prime contract authority

Because

Under the terms of the prime contract, the Institute of Industrial Launderers is charged with the responsibility of developing and providing on-the-job training within its member plants for 1000 mentally retarded workers. the responsibility placed upon the Institute of Industrial Launderers to accomplish these objectives can be thwarted in any region by the local BAT or BES official, the entire prime contract becomes fragmented into many unapproved local-level projects. Accordingly, subcontracts written under the authority of the national prime contract are subject to the approval of local officials and to the possibilities of lengthy delays prior to being approved. The aforementioned Arlington, Virginia, contract being an example in point. As a result of the above, the prime contract in effect has no authority and it seems an injustice to charge the Institute of Industrial Launderers and the Project staff with responsibility and time limits that are not subject to its control. 5. Subcontract procedures and problems

Because of its unique nature, Project Manpower will require certain departures from the generally accepted on-the-job procedures and has been set up accordingly by the Project staff. The objectives of the prime contract cannot be assured unless the project staff is given at least some degree of authority in implementing on-the-job subcontracts to meet the needs of both the participating laundries and the retarded workers which they seek to train and employ. It has been agreed by the launderers to train and employ mentally retarded workers in industrial laundry occupations that are approved by the prime contract. To do this and to assure retention of successful trainees, it is necessary for the launderers to train the trainees in job openings in each plant as they occur. The production requirements of the industrial laundries makes mass group training impractical. The objectives of on-the-job training for these persons would be defeated if simulated special on-the-job training situations were developed especially for them.

Each participating industrial laundry will also agree to train a fixed number of trainees during the term of this subcontract. This number is determined by the anticipated need based on his plants past turnover record. Since this turnover does not always occur in the same job areas nor can these job areas be predicted, it is impossible to predetermine in what exact areas they will be able to offer training. Yet a subcontract, in order to be approved by the regional office, must list the job area in which each trainee is to be trained. This means if a given industrial laundry wanted to train 5 or 6 trainees, starting with a towel counter-folder and one week later would need an extractor operator, he would be unable to fill the extractor operator position with a retarded trainee unless this was one of the positions listed on his subcontract even though it is one of the areas approved for training in the prime contract. Thus, if he were to train an extractor operator, he would have to wait until the subcontract could be amended or a separate one written for this position. Judging from past experience this position most likely would not be open by the time all of this is accomplished.

Launderers contracted to date all prefer to have subcontracts written to cover a period of time of at least one year, but this has not been allowed by regional offices. A six-month time limit is the maximum time allotted for any one subcontract. The dates for beginning and ending must be shown on the subcontract prior to its being approved. This means that many subcontracts will have as much as two to two and one-half months of the allowed time period elapse before a trainee can be started on the job. The Field Coordinator has been told by regional directors that it will take a minimum of 30 days (if lucky) to get subcontracts approved in New York State and 3 to 4 weeks to get contracts approved by their local BAT offices. Add to this transit time and, of course, the time required for the local DVR offices to select and screen and refer appropriate candidates to the program. This may in some cases absorb 50 percent of the training time allowed by a six-month subcontract.

The only reason offered for this ruling by the regional offices was that open and/or long-term subcontracts would tie up the Project's funds and these reserved funds might possibly not be used by the launderers if trainees because of one reason or another were not trained. The Project's perpetual control system is designed so that this would not be a problem. In fact it would allow

the Project staff to get approved enough initial subcontracts to utilize the allocated 1000 trainees. Once this has been accomplished, it would become the staff's responsibility to work closely with the laundries and the departments of vocational rehabilitation to see that the terms of the subcontracts are met as written, and that, if, as is unlikely, some of the contracts fail to reach their quota or be progressing satisfactorily within a reasonable length of time, these contracts could be terminated and the remaining allocations be absorbed by other contracts or new ones written. This latter would seem to be much more efficient and effective because it would reduce the amount of work and time involved in getting subcontracts approved by local BAT offices.

The present system is seen as being at least as uncertain regarding budgeting and definitely more time consuming and by far less convenient for the training facility and project staff than the method proposed by the Project. It is assumed that the prime contract in itself reserves the necessary funds to carry out its purpose without regard to time limits other than the eighteen month limit of the project itself. It, therefore, becomes a bit difficult to plan time schedules in terms of the eighteen months allowed by the prime contract and at the same time conform with that necessitated by the regional offices. It would seem that if the time limits are to be controlled by the local offices that the responsibility for scheduling should also be their responsibility. This would at least allow the Project staff to devote 100 percent of its time to administering Project Manpower programs once they are finally implemented.

Suggested solutions

1. The national BAT office reconsider the above time and job area restrictions and authorize subcontracts to be written on longer term basis to cover any or all job training areas in industrial laundry occupations as authorized by the prime contracts. These jobs to be identified specifically as trainees are placed in them by attachments to the OJT-3A with copies being forwarded to the appropriate BAT regional offices.

2. Authorize the Project Director and/or Field Director to approve the OJT3A proposals and the Institute's Associate Manager to sign the certificate certifying single plant owners authority to sign for his plant.

3. Eliminate the OJT-1 for this Project since the submitted OJT-2A and 3A contain the same information and certainly signify intent. It is felt that the necessity to complete OJT-1, have it signed by the proposer and submit it with the signed OJT-2A and 3A is repetitive and unnecessary.

4. Authorize the Project Director in writing to secure from Regional BES offices blanket certification (training purpose and need) for all subcontracts to be written in their area.

5. That the national representative for the contract secure blanket approval and/or necessary waivers from national unions to implement Project Manpower in plants they represent.

6. Authorize an appropriate BAT national representative to approve Project subcontracts.

7. Authorize the Project staff to keep the regional BAT offices informed of program implementations and progress in their areas by sending appropriate information data and required copies of approved subcontract forms, etc., to these offices by mail to be distributed to state and local offices by the regional office as deemed necessary for local records.

8. Authorize the project staff to support the above by mailing monthly to the regional office a xerox copy of the Project's flex-line Project Control and Data Board which shows perpetually the number of subcontracts with all pertinent data, the names, social security number, sex, and age of all trainees in Project Manpower programs in their regions as of the date shown on the report.

This method, if approved, would allow the Project staff to set up schedules, plan and implement programs in keeping with the terms of the prime contract, the need of the participating industrial launderers, and the availability of appropriately screened trainees rather than for the convenience of the BAT regional, state and local staff.

Summary

It was felt that the approval of the prime contract by the Institute of Industrial Launderers and the National Office of the Bureau of Apprenticeship Training, U.S. Department of Labor, fully established the need for Project Manpower on a national basis and although the Institute in good faith is perfectly willing to abide by and to cooperate with established BAT procedures, ex

perience with Project Manpower to date has indicated that there is a lack of established procedures governing the working relationships between the National Project and regional, State and local BAT-BES offices. The methods and procedures that are established are cumbersome, inefficient, time consuming and deter rather than promote progress.

It seems superfluous to require these local agencies to reaffirm this established national need on the local level at the expense of costly delays in achieving the objectives of the national contract. As it now stands, it is necessary to get subcontracts, written under the authority of the prime contract, approved by the local BAT office and the BES office before these programs can be implemented by the Project staff. The following steps are required by the local offices prior to their approving any subcontracts:

1. OJT-1 must be completed and signed by the plant owner and attached to the subcontracts before the latter will be accepted. This is true even though this form signified intent only and that all information on it is also contained in in the attached OJT-2A and 3A.

2. The participating launderers must be contacted either by mail or in person and the OJT-2A and 3A must be completed and certified by two company officials, even if the president of a company should sign the subcontract another company official must certify his authority to sign.

3. Before this program can be implemented. it has been necessary to meet with the:

(a) Regional BAT director and get his approval to implement the program in that area.

(b) We must then get approval from the state BAT supervisor and/or the state apprenticeship counselor for projects in that state.

(c) Before it can then be implemented, it must be certified as to the need

for this type of training by the state and local BES offices.

(d) After this approval has been secured, we then must be assigned a state or regional BAT representative to whom all subcontracts in that area must be sent for approval.

(e) If there is a union involved, the subcontract must also be approved by that union's local or national representative.

4. Once the above has been completed, and the project staff has been authorized to implement the program, the local DVR office must then be informed of the program in order that they may screen and refer clients for training. Thus every OJT-2A and 3A must be approved and have on it the signatures of the local BES representative, local or national union representative local or regional BAT representative, the industrial launderer that proposed the program and official of his company to certify his authority to sign the proposal.

Transit time and "desk" time on subcontracts submitted to date (only one of which involves a union) has been well over a month with none to date returned as approved. Once they are approved they will still require BES certification before they can be implemented. It is not our desire to sound negative or to imply the lack of willingness to cooperate with established field procedures, but as an organization and staff charged with the responsibility of administering a program as important as Project Manpower we feel that the points brought out in this report are of such a nature they should be reviewed and consideration given them in the same good faith as that in which we submit them. Our primary concern is that of achieving the objectives and purpose of Project Manpower and to obtain maximum return for the taxpayers' dollar which is supporting the project. Accordingly, we are concerned that three months have elapsed with not a single trainee on the job. Because of this we have been unable to write the supervisor's training manual, we have had to delay signing up uncommitted plants because of the staff time consumed in extra paper work, and all due to reasons beyond our control. We, therefore, request a meeting be scheduled with representatives of the National BAT office and the Institute of Industrial Launderers to review the above, that the results of this meeting be put in writing to be used as official policy governing the administration of Project Manpower. Such is felt necessary to protect the good intentions of the Institute of Industrial Launderers and Project staff because present BAT operational policies place both in a position of responsibility without authority.

Senator KENNEDY of Massachusetts. The subcommittee will stand in adjournment until tomorrow morning at 10 o'clock.

(Whereupon, at 11:55 a.m., the subcommittee was adjourned, to reconvene at 10 a.m., Thursday, February 24, 1966.)

EMPLOYER ENCOURAGEMENT FOR ON-THE-JOB

TRAINING

THURSDAY, FEBRUARY 24, 1966

U.S. SENATE,

EMPLOYMENT AND MANPOWER SUBCOMMITTEE,

OF THE COMMITTEE ON LABOR AND PUBLIC WELFARE,

Washington, D.C. The subcommittee met at 10:15 a.m., pursuant to adjournment, in room 4232, New Senate Office Building, Senator Jacob Javits presiding pro tempore.

Present: Senators Kennedy of Massachusetts, Pell, Javits, and Prouty.

Commitee staff members present: Stewart E. McClure, chief clerk; Arnold Nemore, professional staff member; and Stephen Kurzman, minority counsel.

Senator JAVITS. The meeting will come to order.

This is a hearing before the Subcommittee on Employment and Manpower on Employer Encouragement for On-the-Job Training, and our first witness this morning is Mr. Colin Churchill, secretary, Hospital Research and Educational Trust, Chicago, Ill.

Mr. Churchill?

Mr. CHURCHILL. Thank you, Senator.

Senator JAVITS. Will you tell us who accompanies you, sir?

Mr. CHURCHILL. Mr. Edward Weimer accompanies me; he is in charge of the two contracts which I will describe.

Senator JAVITS. Do you have a written statement?

Mr. CHURCHILL. Yes, sir.

Senator JAVITS. Without objection, the statement will be made part of the record and you may proceed as you desire to present your views. Mr. CHURCHILL. Thank you.

STATEMENT OF COLIN CHURCHILL, SECRETARY, HOSPITAL RESEARCH AND EDUCATIONAL TRUST, CHICAGO, ILL., ACCOMPANIED BY EDWARD WEIMER, STAFF MEMBER

Mr. CHURCHILL. My name is Colin W. Churchill. I am secretary of the Hospital Research and Educational Trust, which has two subcontracts with the Department of Labor: One for the preparation of on-the-job training materials, and the other for the training of unlicensed subprofessional hospital employees.

I am accompanied today by Mr. Edward Weimer, who is the man on our staff in charge of both of these contracts.

Before describing the contracts, our experience with them, and ideas about them, I shall say a few words concerning the trust.