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Typical barriers to employment include: limited education, limited occupational skills, outmoded occupational skills, limited English language proficiency, age.

Attachment 2 of this Action Brief spells out where labor representatives and WIBs can get the information they need to determine who in their area is at risk.

It is important to remember that identifying "at risk" populations in a local area is not a one shot activity. Who is at risk changes as the demographic makeup of the area changes (when new kinds of workers move in and others move out) or because of changes in the economy (e.g. when old industries shrink or move away and other new industries move in). Sewing machine operators may not be an at-risk population until all the apparel makers leave town. The Board should have its WIB staff prepare an annual report identifying at-risk populations.

Local unions should inform labor representatives of the needs they see, so the labor representatives can bring these issues and information to the full Board. Labor councils and federations are now convening these discussions in some parts of the country.

3. Determining whether funds are limited and, if so, identifying how to prioritize low-income populations.

In issuing its regulations for WIA, U.S. Department of Labor noted that adult funds are almost universally limited. Therefore each local WIB needs to establish a policy for how it intends to comply with the mandate that when funds are limited, public assistance recipients and other low income adults must be given priority service. This mandate does not apply to the dislocated worker funding stream but only the general funding for adults. In many states, governors and state plans are not dealing with the issues of limited funds, instead providing assurances that funds are not limited. This passes the issue to the local WIB for decision.

What should a WIB do? Except under extraordinary conditions, the WIB should determine funding to be limited and craft such a policy. What kind of policy makes sense? First, the WIB needs to establish low-income guidelines. The best strategy would seem to be to consider anyone who falls below the WIBs self-sufficiency guidelines to be "low income". The advantage of this strategy is that it establishes a clear standard for what constitutes a living wage. Though related, this is a standard of worker need, not job quality.

Second, the WIB needs to consider what other resources some "low income" individuals might have. For example, WIA law says if funds are limited, public assistance recipients are among those who should receive priority. That makes sense only if those public assistance recipients do not have access to core, intensive and training services though TANF, Welfare-to-Work, or other programs. If they do, it makes sense to reserve the WIA funds for those who don't have access to such resources.

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