All right, Cindy, we're going to start up. So, welcome to this public meeting of the consumer product safety commission. We are meeting today to consider a draft supplemental notice proposed rulemaking on safety standards for portable generators. Before we begin, I want to confirm that Commissioner Trump is participating virtually can see and hear us. Again, good morning. Good morning. Portable generator safety has been on this agencies agenda for years. Generators are vital pieces of equipment that are often used in emergencies to keep people safe. Often in the wake of devastating storms or other national disasters or during extended power outage. But most portable generators admit hazardous carbon monoxide at rates that can kill users in minutes. Consumers rely on portable generators to revive light power electronics, preserve refrigerator food and heat homes. They have a right to expect that the generators will be safe for these uses and not themselves present a potential deadly hazard. Look forward to working with staff and colleagues to consider this proposal to develop a strong final rule that will protect consumers from injury and death when they're using portable generators. We have several staff members present in the event. There are any questions in the opening around with this is Janet buyer portable generators project manager directorate for engineering sciences. Also in attendance are Jason Levine, CPSC executive director Austin Schlick, general counsel Dwayne Ray. So deputy executive director actually over there and Alberta Mills, the commission secretary will begin with questions for staff. If there are any, each of the commissioners will have 5 minutes for questions after questions are complete and excuse staff and move to consideration of the draft supplemental notice of proposed rulemaking for safety standards. Portable generators. Once again, I remind everybody it's perfectly appropriate to voice our personal opinions on legal issues, but the vice given to us by the office of general counsel must remain confidential and shouldn't be discussed in a public session. So we'll start now with a round of questions and in this case, I don't have questions when I go down by seniority with my fellow commissioners commissioner Felman. Thank you, Mr. Chair. Other than to thank Ms. buyer for her work on this NPR. I have no questions. Commissioner Trump, you have questions. No, thank you for the tremendous work on this package. I had no questions and commissioner and boil. I don't have any questions either. Mr. Chair. Thank you. So with that, I also will thank you and excuse you and we're going to move to consideration of the package. That's before us. Before, before we're putting this matter as proposed by staff to a vote, I'm going to entertain any motions from the commissioners to amend the staff proposal. I'm going to start by putting forward a manager's amendment that includes proposals from two of my colleagues and ask my staff to distribute copies of the amendment and ask if there's a second for the amendment. Second. Thank you having heard a second. I'm going to ask consent to allow my colleagues to introduce some portions of the manager's amendment. And if you might hold your comments and questions for that purpose, so I'll turn to commissioner Trump the 1st. Great. Thank you. The 1st of the 2 amendments that we have in here solicits feedback from commenters on 2 questions. The 1st question asks for comment on whether there's evidence that portable generator manufacturers vary their production seasonally. I understand the demand can spike around extreme weather events and we heard some suggestion of seasonality of production, but we haven't seen compelling evidence that manufacturers to produce higher volumes of generators. And certainly look forward to learning more there. The 2nd question asks for comment on whether the warning that appears after the automatic shut off feature has been triggered is explicit enough about the danger. There may be some consumers who it's not immediately obvious to them the danger of carbon monoxide if they see that word or those 2 words and if that's the case, I wonder whether it might be more clearly conveyed that danger if we use the word danger or dangerous or poison before carbon monoxide. Or whether the addition of visual representations such as a spelling crossbones, for example, might be useful the 2nd amendment that was included in the manager's amendment. It would prohibit manufacturers from excessive stockpiling by reverting the stockpiling provision back to the commission standard. It's been the commission's new standard practice to define base period as the 1 month out of the last 13 months with the median import or manufacture volume. And it allows companies to import a manufacturer 5% more than that base period. In each month between the final rule and the effective date under our law, it's about as protective as we can get. Now, I'm certainly open to seeing if there's any reason to adjust base period and I could potentially be persuaded if manufacturers submit evidence of drastic monthly production swings, which is why we had that question at the start. But as many deaths as are associated with the product year over year, allowing excessive stockpiling could very well kill people. I don't think we should accept that. So, thank you. Thank you, commissioner. Commissioner Boyle. Thank you, Mr. Chair. My amendment's very straightforward. It seeks additional comment on accessibility for visually impaired consumers who may be unable to perceive a warning lighter of the visual prompt. When a generator shut off due to CO level, so I appreciate. I look forward to comment on that and I appreciate my colleague support. Thank you. Thank you, commissioner. At this point in time, we're going to turn to around for questions and comments on the amendment and I'm going to recognize myself 1st and say that I'm going to, I support this amendment includes additional questions for commenters. And I have no objective to seeking more information for our consideration. Also, propose to bring the proposed stockpiling language in line with the other rules we've recently considered in this package. Staff has made a case about the violent volatility and growth of generator market calls for that calls for a higher stockpiling allowance. And while I understand this argument and note the safety risks that could occur if there was a shortage of available generators doing an emergency. I have less of an understanding as to what the right allowance is, whether it's 105%, 120% or something else. So nor are we certain about the correct base. I urge commenters to provide us with information. The staff may find useful as we developed this whole rule so that the stockpiling allowance can be based on the best possible data. So with that, I'm supporting the amendment. And I turn to Commissioner Feldman. Thank you, Mr. Chairman. I too am supportive of the managers. I have no questions. Thank you. Thank you. Commissioner Trump, do you have any additional comments or questions? I don't. Thank you. Commissioner Boyle. Thank you, Mr. Chair. I do just want to thank Commissioner Trump for his amendments, particularly his continued focus on the stockpiling issues because I think that reflects an important contribution to ensuring that consumers are not at risk from legacy products long after a rulemaking has been adopted. This is an area he has raised repeatedly since coming to the commission. And I do appreciate that focus on consumers. And I also thank him for his other amendment seeking comments. So I support the managers amendment. Thank you, Mr. Chair. Thank you, Commissioner. Having heard no other, does that confirm the round for comments or questions? We're going to move to a vote on the amendment. Commissioner Feldman, how do you vote? I vote yes. Commissioner Trump. I vote yes. And Commissioner Boyle. I vote yes. I vote yes as well. There are four yeses, noes or zero, and the amendment is adopted. Now we go to other amendments by commissioners. I turn to Commissioner Feldman. Do you have any amendments? Thank you, Mr. Chairman. I would like to call up Feldman one for consideration. Great. I'm going to recognize Commissioner Feldman for up to three minutes. Describe the amendment and then ask for a second has been passed out. And then we can move to questions and comments. Thank you. So the supplemental notice that we're considering today asks for comments on a long list of topics. My amendment would add two questions so that commentators could inform us about potential intellectual property. Issues that might affect this rule's ultimate implementation. In crafting these questions, I worked with CPSC staff who raised no objections to including them. If there's someone who holds or could hold IP rights that might affect the timing, cost or availability of others to comply with our rule, we should know that before we finalize it, not after. If licensing of IP could pose a litigation risk that could delay implementation of our rule, we should also be aware of that. If my math is correct, the SNPR is 95 pages long asking the public to comment on these two additional questions, each comprised of two short paragraphs, costs us nothing, asking for comments on these issues won't increase staff's workload. If we find out that there are possible IP issues that could result in some sort of monopoly, it could save a great deal of work on the back end. With that, I'd ask for a second to proceed to consideration of Feldman one. Second. Thank you. Having heard a second, we're now moved to consideration of the amendment. I'm going to recognize commissioners to ask any questions or making comments with respect to the amendment. Then I'm going to come back to Commissioner Feldman at the end. So each commissioner will have five minutes per round and we can have multiple rounds if necessary. So I'm going to recognize myself and say thank you for the amendment, proposing to insert additional questions for commenters as a general matter. I'll support open process for seeking relevant information in a rulemaking proceeding. This issue was raised earlier in the proceeding and I understand that there was no indication of prior to your technologies being used with respect to the standard. I don't know if anything's changed or if issues exist with the standard and you know, it's all relevant all matters. If there's relevant information submitted in the common process, we'll consider it accordingly. I'll support the amendment commissioner Trump. I have no questions. Thank you. Commissioner more. Thank you. Mr. Chairman. I don't have any questions. I will not, however, be supporting the amendment. I do appreciate my colleagues thoughts on this, but I think the questions in the package already on economic impact are sufficiently broad to subsume this issue. And I look forward to commenters who are, you know, certainly welcome to submit comments on this issue. And I think the questions in the package already address allow them to do so in a very clear way. Thank you. Thank you, commissioner and good back to you. Commissioner film, if any final comments, thank you. I'm concerned that this amendment may lack majority support for adoption. And I think that's a mistake. Not only is it a deviation from longstanding commission precedent to include commissioner questions for public comments in our NPRs, but I'm concerned that we might be turning a blind eye to the important competition issues that that may be present. Why should we care for starters? I believe it's universally held that monopolies are inherently bad. Government sanctioned monopoly, which would a mandatory standard would could create would enjoy protections outside of the reach of our antitrust laws. But in terms of our safety mission, they're also important considerations for for for things that we should account for a would be monopolist could raise the price on these products increasing their profits while at the same time limiting the availability of safe and affordable generators for consumers who might need them in emergencies. But I'm also concerned that ignoring a key fact like the IP rights, if they exist, would threaten the viability of a future final mandatory standard because we failed to account for the full cost and subjecting our rule to legal challenge, which we could avoid. I've said it before, but a rule that is state or overturned offers zero consumer protections. Accordingly, I would request a second for the yeas and nays on felt than one. Here in second, we'll turn to a vote on the amendment. Commissioner Feldman, how do you vote? I vote yes. Commissioner Trump. I vote no. Commissioner Boyle. I vote no. And I vote yes. The answers are twos and those are to the amendments not adopted. Turn to any additional amendments. Commissioner Feldman, I have no further amendments. Thank you. Commissioner Trump. Could you have any amendments? I do not. Thank you. And Commissioner Boyle, do you have any amendments? No, Mr. Chair. Thank you. Thank you to all my fellow commissioners and hearing no additional amendments. I move to approve the staff's draft supplemental notice of proposed rulemaking as amended and to direct publication of the same in the federal register. Is there a second? Second. Having heard a second, we can move to a vote. Commissioner Feldman, how do you vote? I vote yes. Commissioner Chonka, how do you vote? I vote yes. Commissioner Boyle, how do you vote? I vote yes. And I vote yes as well. So the yeses are for the noes are zero. The motion to approve staff's draft supplemental notice proposed for rulemaking as amended on portable generator safety passes. The supplemental notice of proposed rulemaking as amended has been approved and shall be published in the federal register. And at this point in time, we're going to have closing remarks 10 minutes for each commissioner and we'll recognize myself for the first 10 minutes. And as I said at the beginning of this meeting, portable generators can be an essential equipment during emergencies. When electric services go out, they provide heat, light, refrigeration, power for phones and other electric equipment. This means also that portable generators are often used during times of stress and disruption. Recently, tornadoes devastated large parts of this country, leaving dozens dead. They left homes destroyed and infrastructure in shambles. Families facing such devastation shouldn't have to worry about the dangers associated with generators they're using to put their lives back together. And we know the generators can be extremely hazardous. Each one can emit as much carbon monoxide as 100 or more cars.  And on average, more than 80 Americans die each year from carbon monoxide poisoning from portable generators. Some particularly tragic cases, whole families have been lost. This agency began evaluating the safety of portable generators nearly 20 years ago. At that time, there is no voluntary standard in place. And this has been a long process, but today represents an important milestone. And that work has largely been done on the work of the staff. And I thank them for all the work they've done during that time. We've approved the publication of a supplemental notice proposed from Lake World making the draws from two voluntary standards, both of which were published in the years that CPSC has been working on this issue. Each standard has strong components, but the staff has evaluated that both could be improved and appears that neither is widely complied with. Staff estimates that if the proposed standard were in place, nearly 100% of the carbon monoxide deaths that we see each year for portable generators could be avoided. We owe it to consumers to try. I expect there will be a robust comment from stakeholders as they examine this proposal and look forward to that engagement and to seeing a final rule emerge later this year. American families shouldn't have to put themselves at risk when they start up their portable generator. And I look forward to working with my colleagues, stakeholders, and staff on this proceeding. Commissioner Feldman, did you have comments? I did. I wanted to thank you for the proceeding today and to say that this is a serious issue. I'm pleased that we're publishing out an SNPR today. I want to thank staff for their work that's gone on for a significant amount of time on this issue to get to this stage today. So congratulations to you. I look forward to reviewing the comments and seeing where we are on the back end of all of this. Thank you very much. Thank you, Commissioner. Commissioner Trumka, did you have comments? Thank you. I'm so proud of the work this agency has done to develop this incredibly strong mandatory safety rule for portable generators. We are talking about a deadly problem. Over 1,300 people died from high-side poisoning caused by 1,004 in 2021 alone. And another 77,000 people heard in that same time period. And it's incredibly troubling to know that a quarter of all those fatal incidents associated with portable generators involve multiple deaths at once, so I'm involving entire families. So this rule that we've adopted today is incredible in the fact that it's going to virtually eliminate that death and injury risk. And emissions limits, carbon dioxide detection, automatic shutoff features. The technology exists. And by requiring companies to incorporate it, the proposed rule will save over 2,100 lives and prevent over 126,000 injuries over the coming decades. And at the same time, it will save American people over 1 billion dollars per year in costs related to those deaths and injuries. It's fantastic. And the agency's approach here should really be a model going forward. Staff designed an extremely protective solution by combining the most protective elements from two voluntary standards. By taking the best of all works and leaving the rest behind, we certainly do right by American consumers. And our amendments today make this package even stronger. After we pass a final rule. Anyway, I feel very strongly that we can't let manufacturers build up stockpiles of the products we would have just determined to be too dangerous to exist. Because if they build up those stockpiles, it delays the life-saving benefits of our rule and it keeps putting people at risk while companies sell off that unreasonably dangerous stock. With portable generators, every unit we allow to be produced and sold without carbon dioxide detection and shutoff features, at that point, we'll run the risk that more Americans will die entirely preventable deaths from carbon dioxide poisoning. So I'm glad we've embraced the Commission's standard stockpiling approach by amendment, which is the more protective approach. And I'd like to extend particular thanks to staff and really particular thanks to Janet Byer, who spearheaded this project over many years. She was steadfast in her advocacy for consumers and her commitment to safety will save thousands of lives here. So this is a resounding win for safety. And I hope we're here discussing a final rule soon. Thank you. Thank you, Commissioner Boyle. Thank you. As I reflect on my own experience with the Commission's multi-year effort to address safety and portable generators, I recognize that we are at a pivotal moment. I want to underscore both the gravity of this hazard and the power of this proposed rule to make a meaningful difference. CO poisoning is a silent killer. A single portable generator can emit as much exhaust as several hundred midsize cars. Over the 18 year period covered by our data, at least 1,332 people have died because of CO poisoning linked to portable generators. These are not abstractions, but real people who turned to generators for help when they were in crisis. During the same period, according to conservative estimates from our data on this hazard, over 17,000 injuries were treated in emergency rooms and over 5,000 patients required hospitalization. And the latest information we have suggests that this disheartening pattern of death and injury continues unabated. Despite wishing that action on this issue could have come sooner, I believe that we are now on a trajectory toward the goal of eliminating this hazard. We can do this. The proposed rule sets clear science-based expectations for manufacturers. It requires them to build safer generators with lower emissions and automatic shutoff mechanisms. The specifics in the rule match up with Sanders developed by industry-led organizations. Not only can we do this, but we must do this to save lives. I welcome comments on the proposed rule that aim to further this goal. And I expect industry to embrace this chance to partner with us in protecting consumers. The importance of safety for portable generators will only grow as demand for them grows in the face of extreme weather events like those we have seen just over the past week. In closing, I want to acknowledge that getting to this point has not been easy. No one knows this better than Janet Byer, whose professionalism and determination over many years at the helm of this project have demonstrated her tremendous commitment to public service and to our agency's mission. We owe our thanks to her and to Barbara Little and to the many others who have done their rigorous technical analysis, carefully reviewed the data, and navigated the ins and outs of the rulemaking process, not to mention those who worked on research, reports, and education campaigns to raise public awareness of life-threatening hazards related to portable generators and CO poisoning. You can truly say that your hard work makes a difference. I am more optimistic than ever about the prospects for progress, and I look forward to a swift advancement to the final stage. Thank you, Mr. Chair. Thank you, Commissioner. Thanks to all my fellow commissioners for engaging on this important issue. And thanks again to the staff who have been working on this package. And with that, this concludes today's decisional meeting of the Consumer Product Safety Commission.


Hi, my name is Brie Thomas and I'm going to go ahead and get started, obviously. I'm really happy to be here today. I haven't been to Atlanta in a very long time. I haven't been to Atlanta since I was a kid and my parents shipped me away for a summer to go and work on my grandfather's chicken farm.  A lot better. So a little bit about my professional background. I am a recovering marketer. I was in marketing and branding for ten years. I've been clean for almost two years. I'm very proud of that. And in deciding to make that career switch I attended a six month super intensive developer training program and I have been formally employed as a real live developer for almost a year. Well just over a year. I work here. Mode said we're a product consultancy and development firm based in Denver. I am the only one on the team with less than 13 years experience. I'm also the only girl on the team. And while that may sound daunting, some days it is, they are an extremely supportive team and I count myself extraordinarily lucky to be learning from Masters of the Craft. I also run the Denver chapter for Girl Develop It helping to bring affordable judgment free professional software education to women and I really enjoy that. I swear this is the last logo slide.  I've been in exactly two apprenticeships since I graduated from the training program and so as a noob, the subject of developer training and growth is very near and dear to my heart. But I find apprenticeships in our industry to be a little on the scary side quite frankly and not just for the apprentice. And that's what I want to talk about today. Specifically, what is so scary about developer apprenticeships? What's missing from them? And at the end of the day, what's important? What should we value in our apprentices and our apprenticeship programs? My hope is that you'll leave here today with maybe some fresh perspective and a few ideas. But first, I'm going to take it back a little bit and talk about the inspiration for this talk because also near and dear to my heart are 80s movies. And the title, Burn Rubber's Does Not Mean Warp Speed was inspired by an 80s cult classic, The Lost Boys. And so I just wanted to take one minute of our time and share that relevant scene with you. Come on, stay here. I certainly don't want to come across as overly dramatic. I mean, developer apprenticeships are not as scary as blood-sucking vampires. Guess it depends on who you ask. I love this scene in the movie because here's this kid, Sam, trying to save his brother and his friends, his family from a gang of vampires. He's got the impending deadline of nightfall upon him. The frog brothers are screaming at him to hurry up and not to mention he just saw a pack of vampires, like, for real.   Like, hey, dudes, I'm going to get us out of here. But warp speed is not necessarily my tempo and clearly not necessarily in the best interest of saving all our asses right now. And so I like to apply this cheeky movie line as kind of a valuable mantra and metaphor in that working hard, being passionate, and being committed, or being scared shitless for that matter, do not necessarily add up to an ability to move at a predetermined speed. And that speed is not necessarily the prime indicator of progress or success, or in the extreme cases, survival. And yet, while I was learning to code in my developer training program, and as well as through both of my apprenticeships, I found myself supremely focused on how fast I was moving. Was I coding fast enough? Was I learning fast enough? Oh, my God, what happens if I don't know all the things by the deadline? Oh, my God, what happens if I don't know all the things? Does that mean I'm not cut out to be a developer? And so it took about 10 months post-grad developer training program for me to chill out on some of that anxiety. Mind you, this is not because I am now a coding sensei, but because I found comfort in the value that I was able to bring outside of my hard coding skills. So I have a background in marketing, law, and client management. And I was able to contribute in a lot of areas, both inside and outside of the code itself. Additionally, I found peace with myself in the rate at which I was learning and the things that I needed to do as an individual to foster that learning. But it was a really tough road getting to that spot, often wrought with doubt and sometimes a crippling fear to even write more code or even speak up about what I was thinking and what I was feeling. And so it was this journey, kind of the self-realization over the last year that made me want to reflect and talk to my teammates and some other apprentices about how developer apprenticeships are perceived, how they're structured, how they're managed, and whether or not we as an industry might be missing some key opportunities to approve apprenticeships. So to get that conversation started, I did a little bit of research. So an apprenticeship is the system of training a new generation of practitioners of a trade or profession. Within on-the-job training approach, usually mixed with some kind of formal study, meaning book study, classroom study, and traditionally apprenticeships would also lead to the procurement of, say, a license in a regulated profession. And it's a system by which a lot of apprentices will launch their careers as most of the training is done while working for an employer who invests in the apprentice in exchange for continued labor for an agreed upon amount of time after the apprentice has achieved competencies that were defined in the program. So the system was first developed in the later Middle Ages, and it came to be supervised by craft guilds and town governments. During this time, a typical apprentice was a fairly inexpensive form of labor, so whereby the master craftsman would employ the apprentice in exchange for food, lodging, and formal training in the craft. And within the entirety of the apprenticeship system, there were some very specific stages and roles. The first obvious being that of an apprentice. In the Middle Ages, an apprentice spent about seven years in this phase. Apprentices were compensated such that they could live reasonably well. Okay, so they weren't worried about where my next meal is coming from. But certainly part of their compensation was the tutelage in the profession.  Following the apprentice years, one would advance to journeymen years. A journeyman is an individual who has completed an apprenticeship and they are fully educated in a trade or craft. But they're not yet a master. So in the Middle Ages, journeymen were often required to accomplish a three-year working trip. Traveling around, gaining experience in a profession across a variety of locations, working with different masters. This phase could actually last anywhere from three years to life. Because, well, the final phase of master was never a guarantee. To become a master, a journeyman has to submit a master work to a guild for evaluation, and then they had to be admitted to the guild as a master. A master craftsman or master tradesman was a member of a guild. And in the European guild system, journeymen were allowed to actually be members of the guild. An aspiring master would have to pass through the career chain from apprentice to journeyman before he could be elected to become a master craftsman. Then, the journeyman would have to produce a sum of money and a master piece before they could actually gain that membership, master within the guild. And if the master piece was not accepted by the masters, they could possibly remain a journeyman for the rest of their life. Also, I chose this picture because I think that you know when you have arrived at master when you can drink and smoke while executing your craft. I work with developers who can cocktail and code. I have not yet arrived. So, delving into the history of apprenticeships got me thinking about some familiar modern apprenticeships and the length of their apprenticeship periods. So, the current Wiki definition cites modern apprenticeships as running somewhere between three to six years on average. So, let's consider some that we're probably all pretty familiar. Who can tell me how long the apprenticeship is for doctors? Just shout it out, people. Seven? Three to eight years. I guess it depends on what kind of doctor you are. What about electricians? Oh, four years. How about traditional engineers? Anyone? Bueller? No, three to five years. Oh, Marty's so excited over there. Three to five years. Okay, last one. Tattoo artist. Don't fail me now. Oh, that's a good guess. It's not. It's one to five years. Okay. So, key takeaways for me as I was reading about apprenticeships is that they take years, like a lot of years, and they're methodical. Okay, there are stages, there are levels, hours requirements, and then an application for master status and licensing. And also that there's a commitment on both sides of the equation to that time in process, including committed in owed time after the formal apprenticeship period. So, if we circle back to developer apprenticeships, and what's so scary about them, I have to start with speed. I think the apprenticeships in our industry are pretty scary. I think the speed is what's so scary, and it originates in many of the modern developer training programs, which are growing at a prolific rate. Everywhere you look today, there are more books, online programs, schools, boot camps, all purporting to turn you into a developer fast, fast, fast. Like to the tune of 24 hours, 10 weeks, three months, six months, and also frightening is that unlike doctors, engineers, electricians, there's no licensing body, no regulations or standards for the quality of curriculum or the quality of student that these programs are producing. And now let's consider formal developer apprenticeships post-grad. Three months, six months, if you're lucky, you'll find one that's a year. I mean, the vast majority are running at three to six months, very few at a year longer, and even more terrifying is that the number of apprenticeships is actually pretty limited. Tons of employers are hiring graduates as fully qualified developers right out of the gate from some of these programs. And so here's what's concerning to me with the speed in this particular context. I think it promotes some dangerous misconceptions about our craft. Like learning to code is fast and fast is easy. And because it's fast and easy, well, then it is clearly a finite endeavor, just something that you can check off the list and go start collecting a check. But as developers, we know that what we do is not trivial.  The learning is infinite and the mastery takes years, like to the tune of 10. And devoting your life to building great software requires a passionate commitment, patience, and conviction. Another scary thing about developer apprenticeships I think are assumptions. David Brinn, scientist in science fiction author said, the worst mistake of first contact, made throughout history by individuals on both sides of every new encounter, has been the unfortunate habit of making assumptions. It often proved fatal. Okay, so I might have a slight flair for the dramatic because I don't really believe that any of the assumptions I'm going to position with you right now have actually proved fatal, but I do think that they're important and I do think they get overlooked and they can result in unintended and negative consequences. A couple of assumptions made by employers. Employers assume apprentices will be vocal and open. And that is not always true, in fact, rarely. Also another assumption by employers. By virtue of being a senior developer, you are well equipped to teach a junior developer. Assumptions by apprentices. Upon graduation from a modern training program, you are immediately employable and handsomely compensated, and most importantly, you are nothing like an apprentice. Another assumption, advancing through levels of developer status, apprentice, if you happen to start there, or from junior level to senior level, for instance, are well-defined transitions within our industry common throughout and easily portable as titles from one employer to the next. Left untreated, assumptions can be a very dangerous thing. Left untreated, they can position you in a pit that you find yourself having to dig out of, and that's kind of scary. So what are some potential consequences that we might find in this pit? Things like a young developer making the wrong choice in job because of a promise of a higher title and or salary and ending up in an environment where they're ultimately set up to fail. Or employer frustration, because progress is not meeting expectations and they have zero input as to why that is. Confusion and anxiety on both sides of the fence about where and how an apprentice actually fits into the larger team. Another scary thing is measurement. Although in and of itself, measurement is not a scary thing, but specifically related to developer apprenticeships. Some things I think are scary are a one-size-fits-all approach. So if we create a standard plan and very specific milestones and very specific skill set bars on a very specific timeline, and then we expect each apprentice to succeed on the plan precisely as it was written, we're likely to find some disappointment because each apprentice is going to be different and each one will have a different learning style and they will bring a different set of strengths and weaknesses to the table. So be wary of inflexibility of a one-size-fits-all approach in an apprenticeship program and mentorship style. Hard coding skills are of course important. But if it's the only thing we evaluate our apprentices by, then we're missing out on some other important factors. For instance, can they integrate with our team effectively? Do we like them? Gosh, do they even like us? Are they creative thinkers? Can we relate to them personally? Are they happy when they come into work every day? And how would you know? Additionally, let's consider other professional skills that apprentices can offer from their respective backgrounds. Take me for instance. So I bring marketing, client management, and even some legal expertise, which were a value add to the team outside of the code base and ended up being pretty critical in our business relationships. So when we consider the value of an apprentice, it's important to think beyond just the hard coding skills. Another scary thing where measurement and developer apprentices is concerned is follow-through. When we say we're going to measure, but then we don't. And this actually happens a lot. It's typically a case of the best-laid plans of mice and men often go awry, meaning at the start of the apprenticeship, it's met with a lot of energy about all the things that make up the program, like weekly check-ins and scheduled mentorship and individual projects and time to read and learn and explore. And then work happens. Or the apprentice just begins producing, and quickly the team loses sight of the apprenticeship because now they have someone producing real work. So let's just keep them, let's let them do that because everyone is so busy in any way really what's the point, and apprenticeship is just on-the-job training, right? But now both employer and apprentice have lost a platform from which to objectively and substantively evaluate progress, contributions, and growth. So what's so scary about developer apprentices? Shotgunning apprentices out the door like fast food, failing to recognize, identify, and address assumptions on both sides of the fence, and neglecting to measure the right things at the right time on the right scale. So what's missing from the apprenticeships in our industry? The mindset of learning a profession versus learning a skill. Many a developer training program can give people some skills, but becoming a successful developer is about learning the profession. And not just with the mindset of trying to bulk up coding skills as quickly as possible, but rather taking the time to mentor apprentices around things like interpersonal skills, your cross-functional team dynamics, and mentoring them around gaining a deep understanding of the business of building software. We're also missing the time to just be an apprentice.  But also real is the investment that you're making in an apprentice. And because of these pressures, the time to just be an apprentice is in jeopardy of being cut short. The demand for developers is high. The junior salary rates and title expectations, many would absolutely say are inflated. Employers and apprentices both are looking for some degree of job security. And yet, so few apprenticeships are structured for any kind of long-term commitment. Much like we might structure a relocation package, we should look for mutually beneficial ways in which to structure longer-term commitments between the parties of an apprenticeship. You know, a promise for something longer than six months. It'll put both sides in a position to focus on what's important in the program, as well as providing for some predictability on the return that the employer is making. Another important ingredient is investing in mentors as teachers. So just because we have a team of seniors doesn't mean we have a team of teachers. And just because we can make a list of all the skills needed to be a fully functioning member of our team doesn't mean we can effectively structure a curriculum appropriately tailored to the individual to achieve that set of requirements. Teaching is a formal skill set is missing from some apprenticeships. We should be looking for ways to invest in our mentors as teachers to give them the ideas and the requisite skills to foster really great apprentices. So what's missing from the apprenticeships? The mindset that programming is more than just slinging code. The time to just be an apprentice and investing in mentors as formal teachers. What's important in developer apprenticeships? We all know that software development is better served with an agile approach instead of a waterfall approach. Our apprenticeship programs are better served as well. Approach the program like you would approach developing a new product. Start with your key stakeholders, mentors and apprentice. Discuss the goals. What are going to be the measures of success? What are the risks? Align on all the most important aspects of the program with a very clear understanding of each person's role in that construct. A mutual and well understood commitment to those goals is critical for success. Also critical for success is diligence in the process. So rigorously implement and adhere to iteration planning meetings at each one. Talk about what went well, what fell short of the goals and then figure out why and how and fix it. And have a backlog and groom that backlog because over time as the team gains insight into an apprentice's specific strengths and weaknesses, now you can adjust the tutelage and the expectations and you can make sure it's reflected in the backlog. Retrospectives, quite simply do them. Use the time to be honest and frank with the team about mentor and mentee pairings. Maybe some are not working well because of particular learning styles. Maybe an apprentice needs more rotation or less rotation among mentors on your team. Use retrospectives as a place for mentors and apprentices to address assumptions, address issues and expectations. And then make some critical decisions that protect the goals of the apprentice, the goals of the employer and the goals of the program. Also important is a two-way street because self-directed learning, it can't be the only thing anymore. The industry moves fast. The demand for top-notch developers is growing exponentially. The expectation of the apprentice will only include self-directed study. An apprentice should exhibit a desire to immerse themselves in the learning and work hard, but the burden of keeping the apprenticeship on track can't just fall on the apprentice. The apprentice needs to know that the apprenticeship is equally important to the employer. An apprentice generally lacks a deep grasp on their importance to the business and this is really unfortunate because when an apprentice feels valued in their role, it has a very positive influence on their performance in the program. An apprentice needs to see an employer's commitment to the construct and they need to feel like the employer is an advocate in that apprenticeship. That the learning investment isn't just important as the apprentice is just as important as the apprentice becoming billable and moving into that role of developer. Holistic value is important. So again, measuring the whole apprentice, it's important not just for the employer but to help that apprentice gain confidence as they're working to bring up their coding skills. For me personally, being able to contribute to the team in other ways was a huge benefit in easing some of my code skill anxiety and it was also critical in moving my focus from one of, oh my gosh, how fast am I going to, okay, am I doing what I need to do to continue progressing. So remember to consider everything that makes up the value of an apprentice. Coding skills, creative problem solving, personality, and last but definitely not least, important in developer apprenticeships is time because burn rubber does not mean warp speed. I spoke with a lot of developers and apprentices as I was working on this talk and I asked them just out of curiosity if they thought it was possible to reach senior developer status at one year and all of them gave me an emphatic no and all of them said they wouldn't even consider someone a senior close to that, maybe not even for two or three years, many said a lot more than that and why is that? Because there is no substitute for experience. Consider Malcolm Gladwell's Outliers if you've read that all the greatest athletes and musicians had one thing in common and it wasn't an innate talent but rather deliberate practice and enough time to get good like to the tune of 10,000 hours or 10 years and consider apprenticeships of the Middle Ages lasting seven years or plus three years in journeyman status before they're even eligible to apply as a master and consider some of the modern apprenticeships that we've talked about today like doctors, electricians, even tattoo artists they invest years in learning their trade and mastering those associated skills developer apprenticeships even if we tack on the developer training program are lucky to amount to one full year but what is it really about the short versus long that's so important? Like if I'm an apprentice why would I bother with a long apprenticeship over a short one? That bump in title means a bump in salary why would I waste years if I could accomplish it in a matter of months? Conversely, if I'm an employer why would I invest in the prospect of years over months? What's in it for me? How can I justify an investment of that size? I think because learning to play the notes for an instrument is not the same as being a musician learning to play is but the first and arguably the smaller hurdle applying that skill over and over and over again gaining performance over time is what marks the difference between one who can play an instrument and one who can make music the intangible elements of communicating a vibe a feeling or riffing something new off of an existing song that's the mark of a great musician and you need that runway it's a business relationship between employer and apprentice and the common goal should be one of building a better developer a well-paid developer who can exercise autonomy and also integrate seamlessly within any team a developer who stretches beyond just the task itself and exhibits thought leadership a creative developer capable of applying a systems view in solving the problem and vision in what the finish line looks like and how to get there and the apprentice who becomes this developer is a valuable asset and right now today can write their ticket almost anywhere and the employer who fosters this kind of apprentice is well positioned to retain them for the long term which is definitely worth the investment and certainly more economical so what's important in developer apprenticeships an agile approach and diligence in that application the two-way street put into what you want to get out and that doesn't just mean the apprentice the artistic value measure more than just the hard coding skills and lastly favor the marathon we know becoming a great developer it's not a sprint it's a marathon so let's find ways in which to construct apprenticeships that are less about sprinting and more about a long-term commitment between teammates so I've talked about what's scary, what's missing what's important in developer apprenticeships I hope that some of it was fresh perspective but I also promised you some ideas so here are a few thought starters that I brainstormed with my team and some of them strike you as too radical well then I hope that they at least plant a seed of ideation as you think about creating or adding to some of your apprenticeship programs start at two out of the gate structure your apprenticeships for two years pay the apprentice well but you don't have to be obnoxious if you want to give them a pay increase after six months or one year for whatever reason great do it but don't change their title keep them titled as an apprentice for two years with an option to reapply for continued apprenticeship after they complete the program or if you feel like they're ready let them begin working off their owed labor of one year as a developer on your team that's right start at two but contract for three treat your apprenticeship program like a product integrated into the fabric of your business and the team make sure your team knows when they get hired with you that mentoring is part of the job and as such you're going to give them the tools they need to be good at that job and conversely they're actually expected to help foster and improve that product over time and I think this is really important I think you need the team to take some ownership and realize accountability in the apprenticeship program for it to be successful hire a teacher and teach your senior mentors lots of teachers have their summers off I'm sure they would love to make consultant rates to come in and do some workshops with your team they don't have to be developers necessarily but find someone who can help your team think about and structure a long term curriculum and evaluations to support that curriculum and to give you some pointers on how to engage with students of various learning styles if you don't know any teachers then reach out to a place like Turing they know a thing or two about teaching students the point being is don't underestimate the skill it takes to be good at teaching and so seek advice and invest in that include the idea of a journeyman in your apprenticeship program but focus it internally so what I mean is have your apprentice travel around to various teams especially departments if applicable at your company encourage the development of skills outside of just writing code if you happen to be a large scale product company lots of different development teams give them time to bounce from team to team understand the varying dynamics and kind of figure out where maybe they would fit in best and if you're a small consultancy bring them to new business meetings include them in parts of the process that are not just about writing code like design, research, testing because a well-rounded apprentice can become quite the valuable developer thank you