The DAS 140 form is a necessary document for contractors who have been awarded a public works project and will utilize an apprenticeable craft. The purpose of the form is to inform local apprenticeship committees which trade of apprentices will be required for the project. Contractors must submit the form before staring work on-site to the apprenticeship committees closest to the project site, regardless of the contractors main location.
It is essential to complete the form fully and save proof of submission as incomplete or missing forms are considered non-compliant. Non-apprenticeable trades must provide a letter stating they are exempt, while apprenticeable trades claiming exemption must still fill out the DAS 140 and attach a letter explaining their exemption. Contractors who fail to comply with apprentice requirements may face severe consequences, such as fines, penalties, suspension of licenses, legal action, and damage to their reputation.
By completing and submitting the DAS 140 correctly, contractors can ensure compliance with apprentice requirements, which can establish a positive reputation and secure future contracts. It is crucial to avoid leaving any sections blank or using “TBD,” and proof of submission should be saved and available upon request. Non-apprenticeable trades should provide a letter stating they are exempt, and those claiming exemption should fill out the DAS 140 and attach a letter detailing their exemption. It is important to have readily available proof of exemption upon request.
Now that the purpose of the DAS 140 is clear, here are some helpful tips on how to remain in compliance with the requirement.
- First and foremost, an incomplete submitted form is the same as an unsubmitted form. If the form has any missing sections, or sections filled in with ‘TBD’ this is deemed non-compliant and the same as not submitting the form at all. When it comes to dates or man hours, estimates are accepted and generally expected.
- The second most common mistake contractors make is by not saving proof of submission. If the project gets called in for audit, they will require proof that the DAS 140 was submitted to the apprenticeship committees. This proof can come in the form of read email receipt, certified mail receipt, or fax transmittal sheet.
- Finally, what to do if you are a non-apprenticeable trade? What if you have an exception? Here’s what not to do, don’t fill out the form with ‘n/a’s or ‘for compliance purpose only.’ If you are a non-apprenticeable trade, have a letter written out simply that your trade is non-apprenticeable and this requirement does not apply, attached a copy of that project’s wage determination and you are in the free and clear. If you are an apprenticeable trade, but are claiming an exemption, you MUST STILL FILL OUT THE DAS 140. Fill it out like normal, as if you would be hiring apprentices. It is the DAS 142 (the dispatch form) you will not be filling out. To satisfy the DAS 142 requirement, have a letter that details your exemption and attached the exemption to the letter. Remember, it is not enough to simply claim a requirement does not apply to you, ready made proof must be available upon request.
For more information on managing a public works job, please contact Teresa Osso | Manager of Labor Compliance
949.398.6729 | firstname.lastname@example.org