Winners of Mayor of London Adult Learning Awards 2023 revealed

An inspiring refugee college student who lost eight fingers and both legs is among the winners of the second annual Mayor of London Adult Learning Awards.

The awards, sponsored by FE Week and Ascentis, aim to recognise inspirational Londoners and excellent London-based providers for their contributions to adult learning in the capital.

Winners of the 10 award categories were joined by their families, employer representatives, the judging panel, Morley College’s Big Band and stakeholders from London’s education and skills sector at a ceremony at the City Hall headquarters in east London on Thursday evening.

The awards were established last year by the Mayor of London Sadiq Khan as part of his commitment to improve skills in London and the ‘Skills Roadmap for London’ strategy.

Earlier this summer, officials at the Greater London Authority and Learning and Work Institute assessed nearly 300 nominations to create a shortlist.

A judging panel, made up of representatives from London’s skills sector including AELP chair Nicky Hay, City Lit principal Mark Malcomson, and last year’s award winner Ghazal Mottaghi, then met virtually in September to agree on the winners and highly commended finalists.

Among the winners was Nabeel Ahmed, who received the inspirational adult learner of the year award. After coming from Pakistan to the UK alone and disabled after losing eight fingers and both legs due to frostbite in a refugee camp, Ahmed excelled in an ESOL course at New City College, which gave him confidence and more independence.

(L to R) Will Gompertz, Nabeel Ahmed, Pablo Lloyd OBE, ©2023, London, UK. 2nd November 2023. Adult Learning Awards ©GLA/Andrew Baker

“Studying has given me my life back,” he said. “Without this course I do not know where I would be.”

“Because I have to sometimes use a wheelchair or my artificial legs, this has enabled me to become more independent in my life and has given me hope that I will be able to find a job soon.”

London Skills and Development Network (LSDN) was awarded distinguished provider of adult education for its achievement in reducing reoffending amongst the existing and ex-offenders engaging with the not-for-profit social enterprise.

LSDN works with learners from recovery services, women’s shelters, rehabilitation centres, homeless centres, and probation services. The judging panel said they were impressed with its holistic approach and awareness of net zero on its green campus.

The Learning for Good Work Employer of the Year award went to SEND Coffee, which trains young people with a disability to be baristas and helps them into further employment. Founder Harry George was praised by judges for his inspirational and entrepreneurial approach.

SEND Coffee, ©2023, London, UK. 2nd November 2023. Adult Learning Awards ©GLA/Andrew Baker

Waltham Forest College was given the highly commended award in this category for its commitment to apprenticeships. The college employs around five per cent of its 320 staff through apprenticeships.

“The way they have adapted the workplace and supported their staff around the cost-of-living crisis stood out,” judges said. “They had clear data on the impact of their approach.”

Meanwhile, Anastasiia Trubkina won the Inspirational Tutor in Adult Education award for her ESOL teaching at MI ComputSolutions. Trubkina fleed Ukraine last May and volunteered in a humanitarian organisation to support eastern Europeans before joining MI ComputSolutions.

Phil Wilkinson (Ascentis CEO), Anastasiia Trubkina, Pablo Lloyd OBE, ©2023, London, UK. 2nd November 2023. Adult Learning Awards ©GLA/Andrew Baker

As a former English teacher, her passion for teaching was reignited at the company and also she helps learners into employment and other Ukrainians to settle into the UK.

The Mayor of London is responsible for the £320 million per year adult education budget for the capital after taking over in the devolved budget in 2019.

The budget included a cost of £300,000 for the GLA’s recent learner survey which found over half of non-retired adult learners had a positive economic or educational change after their course.

Is ‘good’ good enough to encompass the range of practices in FE?

In further education, the pursuit of excellence is a noble endeavour. Yet as we navigate the intricate landscape of Ofsted-graded institutions, a crucial question is whether ‘good’ or grade 2 is too wide for the range of practices is encompasses. At one end, ‘good’ reports read as great – or just shy of ‘outstanding’. At the other, they verge on something much less desirable.

The current four-point grading scale characterised by one-word judgments has been a fixture of our education system for many years. Calls for change (including those before the commons select committee from former Ofsted head Sir Michael Wilshaw last week) resonate. Incoming chief inspector, Sir Martyn Oliver has told the same MPs that he is unconvinced by the arguments, but his promised “big listen” should delve into the nuances of inspection reports to understand how closely or distantly an institution aligns with its assigned grade.

A deceptive clarity

At first glance, a simple grade seems like a straightforward assessment of an institution’s performance. However, the reality is more complex. This is why the Fellowship of Inspection Nominees (FIN) dissects inspection reports to uncover the details that really matter.

Examining published inspection reports from 1 September 2019 to 31 August 2023, we find compelling data. Over this period, there were over 1,300 inspection reports in total with 107 institutions (8 per cent) graded as ‘outstanding’. Breaking down the numbers by institution type reveals interesting insights, with sixth form colleges clearly leading the way in terms of the top grade.

When considering the type of provision delivered by the best performers, the data could suggest that the education inspection framework is more aligned to delivering full-time education to under-25s and less applicable to apprenticeship delivery. Learning on the job, at a variety of levels and at all ages is not such a snug fit.

In the same four-year period, inspections resulted in 64 per cent of all FE and skills providers being rated ‘good’, far outstripping those deemed ‘outstanding’, the 22 per cent judged as ‘requires improvement’ and the 6 per cent deemed ‘inadequate’ – individually and indeed collectively.

Are all ‘good’ providers really on a par with each other?

This begs the question: are all ‘good’ providers really on a par with each other? Does a ‘good’ grade imply a uniform standard of service across the board? In our view, the answer is not as straightforward as it seems.

Inspection reports have underscored this by throwing up some interesting examples and definitely revealing a spectrum. At one end, inspectors praised one grade 2 provider for its “welcoming and respectful environments” where learners “develop positive professional relationships with their trainers who support and motivate them to strive highly and achieve” – a clear indication that the right learners are enjoying the right programmes and succeeding. In contrast, another institution was also rated ‘good’ despite inspectors querying its levels of programme completion and whether the provider was using reasons for non-completion to improve its practices.    

Does ‘good’ require improvement?

So is there room for a more precise differentiation between ‘really good’ and ‘only just good’ to accurately reflect the quality of leadership and operational delivery? Would this provide more clarity to potential learners and employers selecting provision, or to potential funders to give them confidence that a provider’s plans for growth are combined with integrity?

While grade 2 is commendable, especially for those who genuinely deserve it, it’s pleasing to see providers continuously strive for excellence. It’s also encouraging to see many who achieve ‘good’ looking for ways to further strengthen provision and aspire for a higher grade.

Equally, we should applaud those achieving ‘outstanding’ who work tirelessly to maintain exemplary standards and stay one step ahead. Lowering the bar to let more into that category would only devalue the category and their work. However, there is a good case for reviewing whether it is the rigidity of the EIF rather than the quality of provision that locks very good apprenticeship providers out of that band.

For all these reasons, Ofsted’s “big listen” should establish whether providers and employers agree that the scope of grade 2 is too wide.

Every pound raised through the levy should be spent on apprenticeships

Since its introduction in 2017 there has been a lack of transparency as to how monies raised through the apprenticeship levy are spent. This has led many employers and employer groups to claim that a significant proportion of the levy they pay is ’wasted’.  

Of course, money raised from levy-paying employers is also used to fund apprenticeship provision for non-levy-paying employers. Employers have always needed to understand that. Nevertheless, there is some validity in the claim that some of the income raised by the levy is not being spent on apprenticeship but is instead being retained by or returned to the Treasury.

In a recent article, FE Week reported that last year £415 million raised through the apprenticeship levy was not allocated to apprenticeships, but instead “pocketed”by the Treasury.

These figures are telling. Of course, they do change year on year, but the constant is that the Treasury always wins. So, what needs to happen?

A commitment to transparency

To bolster confidence in the levy system, employers and training providers must know how much is raised through the levy and how funds are used. There is an urgent need for the DfE and Treasury to provide detailed figures and ongoing analysis on revenue raised, monies raised minus funding allocated to the devolved governments, the value of the apprenticeship budget and monies spent on apprenticeships. In addition, we need analysis of apprenticeship funding spent on non-levy-paying employers, in different regions, on different levels and on different apprenticeship standards. 

A re-commitment to the levy ‘agreement’

When introduced, the levy was sold to employers as a hypothecated tax, paid to fund apprenticeships. To safeguard confidence in the levy system, government should make a commitment that every pound raised through the levy will be spent on apprenticeships and that any surplus levy will be spent on related designated training programmes. 

At a superficial level, England’s budget is under-spent – as it has been since 2017/18. In reality there are several areas where funding is needed:

  • Raising funding bands to ensure that apprenticeship standards are financially viable to deliver. Given recent and current inflation levels, IfATE needs to undertake an urgent review of apprenticeship funding rates and advise on action needed to ensure that the delivery of all apprenticeship standards remains financially viable.
  • Funding entry-level programmes that provide access to intermediate apprenticeships. This is not a UVAC area. We are, however, conscious of the need to do more to support those who are not yet ready for an apprenticeship but could benefit from one if an access programme was provided.
  • Investing in developing provider capacity for apprenticeships that deliver the net zero and green jobs agenda. Apprenticeships should be a key programme to support the country to deliver these ambitions.  Levy funds could be used to support the development of capacity to do so.
  • Providing incentives to encourage employers and training providers to use apprenticeships to support social mobility. Levy funds could stimulate the use of apprenticeships in deprived areas as part of the levelling up agenda.  They could also be used to incentivise apprenticeships where there would be a significant positive impact on social mobility and workforce diversity.

The Labour Party and the Liberal Democrats and have put forward proposals to reform the apprenticeship levy. For example, Labour has proposed the introduction of a ‘Growth and skills levy’ where employers could spend up to 50 per cent of their levy payments on approved non-apprenticeship training. 

Whether sufficient funds would be available to use 50 per cent of levy income on other training without reducing spend on apprenticeships is questionable. In 2022/23, 83 per cent of monies raised through the levy after allocations to the devolved governments was spent on apprenticeships in England. 

First and foremost, the priority should be to ensure apprenticeship levy funds are spent on apprenticeships. However, the argument that any surplus funds should be spent on designated training programmes needed by employers rather than simply returned to the Treasury is appealing. 

Improved transparency from government would be a welcome first step towards an open and informed debate. 

Storm Ciarán causes college closures

Gusts of more than 80 mile an hour winds have forced eight colleges to close their campuses today, as storm Ciarán hit England.

At least six further education colleges shut their doors to ensure students and staff are safe, with another reminding students to “only travel if safe to do so”. Two sixth form colleges closed their doors as well.

Storm Ciarán hit the south, south east and south west of England on Thursday morning, with gusts of up to 85 miles an hour and high rainfall affecting coastal areas especially. The Met Office issued amber and yellow severe weather warnings for areas across the south of England. An amber warning means there is a “potential risk to life and property”. Colleges soon started closing their doors for the day.

Multiple campuses of Chichester College Group, which teaches around 25,000 students, were shut on Thursday, with them all moving their lessons online.

The group closed its colleges in Chichester, Brinsbury, Northbrook, Crawley, and in Haywards Heath, while Brighton Metropolitan College also shut its doors. The college said it would be “open for staff who are able to come in” but that they could also work from home if travel is not possible.

“The safety of our students and our staff is our priority, and while this decision has not been an easy one, we feel it is the right one,” the statement added.

Cornwall College, which has nine campuses and more than 15,000 learners on its books, also closed all campuses apart from those in St Mellion and Lindfield. It also said staff should only travel “when safe to do so”.

Isle of Wight College, which has around 4,000 learners, meanwhile closed its two campuses in Newport and in East Cowes.

Sparsholt College Group, too, shut its doors on Thursday at both its Andover and Sparsholt campuses, and switched its 5,000 leaners to online courses. Julie Milburn, the college’s chief executive, said she is “mindful” that many students and staff travel “significant distances” to the college. 

“[We] want to both keep everyone safe and ensure learning is not disrupted by partial attendance,” she added. The college also cancelled all arranged transport for the day.

The newly formed South Hampshire College Group (SHCG), which has more than 14,000 learners, closed two colleges – City of Southampton College, and Eastleigh College. In a statement on X, formerly known as Twitter, City of Southampton College said it was closing “in full”, and that all learning “will be set online for students and apprentices to work on at home”. It advised its students to check their emails for more information. The same applied to Eastleigh College. 

Brockenhurst College, which has more than 8,000 learners, also closed its campus and moved all learning online. In a statement on its website, it said it expects to be open as usual on Friday 3 November.

Though it stayed open, Truro and Penwith College told its 8,000 students in a statement on X to “only travel if safe to do so”. 

Sixth form colleges, including Peter Symonds College, and Itchen College, also closed.

Starts stopped on 18 apprenticeships with no assessment organisation

The government has paused starts on 18 of the 78 apprenticeships that have no approved end-point assessment organisation.

Banners have been placed on the Institute for Apprenticeships and Technical Education’s web page for each standard the new rule applies to, which are mostly unused apprenticeships including assistant puppet maker, historic environment advisor, and storyboard artist.

The apprenticeships quango claimed there are “no apprentices currently on programme” for those that are subject to the pause. 

However, Department for Education data shows there were 10 starts on the 18-month specialist rescue operative standard in the first three quarters of 2022/23, and some on the 24-month knitted product manufacturing technician apprenticeship.

IfATE did not respond to requests for comment about what happened to those apprentices at the time of going to press.

It is also not clear why the institute has not paused starts on all apprenticeships that do not have an EPAO in place yet.

FE Week analysis of DfE data shows there are 78 standards approved for delivery with no organisation in place to do their end-point assessment, several of which have apprentices on programme (see table below). Twenty eight of those 78 do, however, have an EPAO in place “in principle”.

‘Special dispensations’ for affected apprenticeships

A previous FE Week investigation warned that scores apprenticeships were launched without an EPAO signed up to deliver their end-point assessment when standards – the replacement to old-style frameworks – got off the ground in 2014.

We exposed cases where apprentices had to wait more than a year for an organisation to test them and others who missed out on a pay rise because there was no EPA ready for them.

It led to the government announcing in 2019 that it would only fund starts on apprenticeship standards that do not have an approved EPAO if the training provider has an “in principle” commitment from one applying for approval.

The IfATE’s “quality strategy”, also published in 2019, states that employers should have access to at least one EPAO before apprentices start their programme.

IfATE told FE Week today that if there was ever such a situation now where an apprentice got to the end of their programme without an EPAO in place, it would work “at pace” to put alternative arrangements, such as the “special dispensations” offered during the Covid pandemic, in place.

A spokesperson said: “Where a temporary dispensation is required, our policy is to stay as close to the original EPA as possible, acknowledging that some changes may be necessary to support apprentices to complete. Arrangements would be discussed and agreed with employers to make sure the EPA still holds their confidence as a measure of occupational competence.”

IfATE suggested the trouble with attracting EPAOs to the apprenticeships in question reflects the situation with starts – there is no appetite for them.

A statement about today’s announcement on the institute’s website said: “IfATE and DfE are moving to a position where apprentices should only start on an apprenticeship where an EPAO is confirmed.

“It follows our commitment to improving the quality of end-point assessments and securing the best experiences and outcomes for apprentices.

“This will require starts to be paused on a limited number of apprenticeships with no EPAO in place, and no apprentices currently on the programmes.

“It means apprentices will not be able to begin on them until an EPAO is found.”

(Click to enlarge image below)

Apprenticeship assessment arm of GP Strategies to close

The apprenticeship assessment arm of GP Strategies will close its doors at the end of January, it has been announced.

It comes after the company, which is part of Learning Technologies Group (LTG) plc, pulled out of apprenticeship training delivery earlier this year following a damning ‘inadequate’ Ofsted report which found “demotivated and disengaged” apprentices walking away from their courses.

The firm has now also decided the shut its end-point assessment (EPA) division. Exams regulator Ofqual published a conditions notice today that said GP Strategies would “surrender recognition in respect of all its regulated qualifications” by January 31, 2024.

The assessment arm, which trades as GP Strategies Assessment Services Limited (GPSAS), completed 720 EPAs between March 2022 and February 2023, Ofqual data shows. It had offered EPAs in adult care, business administration and project management, from levels two to five.

The decision means GPSAS will not be able to complete any EPAs from the end of January, and will not be able to register any more learners for its EPAs, as of October 31.

In a statement on its website, the firm said it was closing its EPA provider “with mixed emotions”.

“Rest assured, we will work closely with our clients to continue to provide support and assessments for registered learners,” the statement added. “We understand that this may also cause some disruption and uncertainty for apprentices, who should contact their training provider for further information.”

GPSAS vowed to ensure “a seamless transition and minimis[e] any disruption” for its apprentices and clients.

Ofqual’s notice said GPSAS is now required to “take all reasonable steps to protect the interests of apprentices in relation to its qualifications” and comply with a “written withdrawal plan, which must specify how the interests of apprentices will be protected”.

The organisation must also provide “clear and accurate information about the withdrawal to apprentices, training providers, and purchasers of qualifications who are likely to be affected by the withdrawal”.

GPS Strategies’ apprenticeship training provider was teaching almost 5,000 apprentices at the time of its decision to exit the market. Around 95 jobs were lost when it closed.

It is not clear how many jobs are at risk amid the closure of GPSAS. The company has been approached for comment.

LTG bought GP Strategies in October 2021. At the time it said the acquisition would help the business generate a revenue of around £500 million.

Tory donors leave Education Policy Institute board as election looms

Two prominent Tory donors will step down from the board of the Education Policy Institute, the think tank has announced.

Hedge fund boss Sir Paul Marshall, EPI’s co-founder and chair, and Lord Nash, a former academies minister, will step down as trustees on December 31.

David Laws, the former Lib Dem schools minister, will also step down as executive chair of the think tank, but will move into Marshall’s chair of trustees role from January 2024.

The changes come ahead of an anticipated Labour win at the next general election, which must be held by January 2025 at the very latest, but is likely to be either in the spring or the autumn next year.

David Laws
David Laws

The EPI was formed in 2016 when CentreForum, a Liberal Democrat-aligned think tank, was repurposed to focus on education policy.

It started with Laws as executive chair and Natalie Perera, a former senior government adviser, as its executive director. Perera remains the charity’s chief executive.

In a statement, the think tank said it was “delighted that David will continue to have a pivotal role in the oversight and governance of EPI”.

They said they were also “truly grateful for the support, generosity and commitment that Paul [Marshall] has shown to EPI since its inception”.

“Lord Nash will also be stepping down as a trustee from December 31 and we are very grateful to him too for his time and generosity over the years. We will be making further appointments to the board in the new year.”

Trustee’s journey from Lib Dem to Tory Brexiter

The departure of Marshall – once a prominent Liberal Democrat supporter – follows a switch in his allegiance to the Conservatives following the 2016 Brexit referendum.

Marshall gave more than £170,000 in cash and non-cash donations to the Liberal Democrat party and politicians including David Laws, Sir Menzies Campbell and Nick Clegg between 2003 and 2015.

He also gave £90,000 to the unsuccessful campaign in favour of an alternative voting system in 2011.

Unlike the Lib Dems, Marshall went on to back Brexit, giving £200,000 to Vote Leave Limited.

He then donated £3,250 to former education secretary Michael Gove’s Conservative leadership bid in 2016, and also gave him £10,000 in 2019. That year, he also donated £500,000 to the Conservative Party.

Marshall is also a major shareholder in GB News and served briefly as its interim chair. He also owns the news website UnHerd and has been touted as a potential future owner of the Telegraph newspapers.

He is a trustee of the Ark academies trust and was previously lead non-executive director at the Department for Education.

Nash, who was academies minister between 2013 and 2017 and founded Future Academies, donated £38,000 to Conservative politicians, also including Gove, and the party itself between 2006 and 2016.

He gave £40,000 to the no campaign in the 2011 alternative vote referendum. His wife Caroline has also donated £216,250 to the Conservatives.

Sir Ian Bauckham appointed interim Ofqual chief

Sir Ian Bauckham will become interim chief regulator of Ofqual from January, the organisation has announced.

The academy trust boss, who currently chairs the regulator, will take over for a 12 month period after Dr Jo Saxton leaves to become head of the University and College Admissions Service.

Bauckham will stand down both as Ofqual chair and chief executive of Tenax Schools Academy Trust, which he has led since 2015, to take up the new role. It is not clear if he will also leave his role as chair of the Oak National Academy.

Education secretary Gillian Keegan announced last month that the next boss of Ofqual would serve in an interim capacity for a year because of “the challenge of recruiting an experienced suitable candidate to such a high profile and a challenging role on a short-term basis”.

The public appointments process for a substantive chief regulator “will commence shortly”. 

Saxton announced in September she was standing down after just over two years in the job, leaving limited time for a full recruitment process.

‘A career devoted to advancing education’

Bauckham said his “entire career to date has been devoted to advancing education”.

“It is an honour, therefore, to be invited to serve as chief regulator of qualifications by the secretary of state at such an important time. 

“Qualifications, supported by regulation, open doors and transform life chances for students. I will be pleased to build on the existing working relationships I have with colleagues both within Ofqual and across the sector in this new capacity.”

He added he looked “forward to continuing Jo’s good work, and am fully committed to using Ofqual’s powers to regulate on behalf of students and apprentices”.

Bauckham will be Ofsted’s fifth chief regulator in four years.

Sally Collier resigned in 2020 over that year’s grading fiasco, and was replaced on an interim basis by Dame Glenys Stacey, who was also her predecessor.

Simon Lebus replaced Stacey, again on an interim basis, in January 2021, and then Saxton took over in September of that year.

Keegan said Bauckham’s experience “will be invaluable as Ofqual continues to ensure our current qualifications work effectively, alongside playing a vital role in the development of our new Advanced British Standard”.

“I’d like to thank Jo for guiding Ofqual through the challenges that followed the pandemic and ultimately overseeing a smooth return to exams and normal grading.”

Ofsted publishes first FE curriculum review

Ofsted has published its first curriculum research review for further education, focusing on business.

The watchdog has published research reviews for the school curriculum since April 2021 and has now started the same work in post-16. More are expected in the coming months.

Ofsted made clear the reviews are not inspection “instruments” and inspectors do not grade subjects.

Rather, they review the quality of curriculum design, teaching and impact in a range of subjects and provision types. This enables them to “identify and evaluate systemic curricular strengths and areas for improvement in a provider”.

Today’s review says business education is “one of the largest subject areas”.

The government does not provide data just for business courses, but more than 450,000 people signed up for courses in FE in the business, administration and law sector subject area in 2022/23. 

Qualifications in the sector are available from levels two to seven. 

Here’s FE Week’s speed read of Ofsted’s review.

1. Maths knowledge crucial to ‘rapid progress’ in business

Ofsted stressed that solidifying maths knowledge is a crucial part of business teaching.

The regulator said “cross-cutting” concepts, which involve building core knowledge in maths before going onto business education, are required to drive “rapid progress” in the business sector. 

Good business teachers “identify and teach the mathematical knowledge a learner needs” and then teach its use in business. Ofsted gives the example of teaching percentage change before using that to teach elasticity demand.

Less effective providers however say mathematical knowledge is “embedded” in their courses but not taught explicitly.

2. Learners need to be on the right course

The review shows that “most providers” in England enrol their learners on the right courses. But it does identify “a few cases” where providers put learners on level three team leader programmes because they can not offer level two business apprenticeships.

Learners may then study curriculums which are “too hard” or they “may not be in roles that give them the necessary learning opportunities”. That would risk holding back learners from completing their courses.

3. Linear progress ‘key’

Providers of business apprenticeships should “coherently plan” their curriculums so that learners can move forward to more advanced levels without having to repeat or miss any learning.

At some “weaker providers”, that does not happen though – meaning the topics covered do not always contain “more challenging theory or breadth as the levels increase”.

For instance, some level seven providers might assume that all apprentices are ready for lots of independent learning.

The regulator does acknowledge that most curriculums “ensure a smooth transition as learners progress to higher levels”. As it progresses to higher levels that would mean a “broader and more strategic focus” with an “expansion of responsibility”.

4. Courses should cover ‘business or strategic context’

Ofsted warned that courses are less effective if the “wider business or strategic context” is not applied to learning. 

Good accounting courses should include a considerable variety of content covering bookkeeping, accounting, budgeting and cashflow management, for instance. As well as that, any “ambitious curriculum” should include explanations of how different management financial tools are linked.

“These providers know that it is the strategic/holistic view that helps learners to develop expertise in business education.”

5. Work and study need integration

Teaching should be married with the time spent at a workplace, Ofsted said.

Teachers who are effective “give learners plenty of opportunities to practise and build their skills” over time, to help learners at work. Using case studies, life briefs and simulations are crucial when it comes to developing learners’ skills so they can “select the right knowledge to apply in different contexts”.

By using role plays at college, teachers can develop learners’ knowledge and skills, before they are exposed to live business decision making.

The report warns that in some “weaker providers”, there are “weak links” between the on-the job and off-the job training. “In the weakest provision, the apprenticeship curriculum is viewed as a separate piece of training or study that is parallel to work but not integrated sufficiently.”