CONSTRUCTION DIVISION MEMORANDUM

GENERAL SUBJECT: TRAINEES ON CONSTRUCTION PROJECTS NUMBER: CD-94-4
SPECIFIC SUBJECT: UTILIZATION AND COMPLIANCE DATE: MARCH 7, 1994
Original w/Signature on file in Construction Division
C. F. GEE
CONSTRUCTION ENGINEER
DIRECTED TO - DISTRICT ADMINISTRATORS
When Special Provision for Section 518 Trainees on Construction Projects is included in a contract, the Department normally expects the attainment of the training specified. In some circumstances, however, there may be legitimate reasons why the Contractor is unable to obtain all, or indeed any, of the training required. An example of such a situation would be when a company is not hiring at all, or is only hiring back previously laid off employees in accordance with written company policy, and all current project personnel are trained to their maximum potential. In instances such as these, the Contractor is to adequately justify such failure to the District Equal Opportunity Coordinator (DEOC) involved. On federal aid contracts in particular, the DEOC must then review this information in conjunction with the Contractor's overall EEO posture prior to making a compliance determination regarding the trainee provision.
On contracts with no trainees required, the Department may, upon request from the Contractor, provide for such training through a work order.
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