The Department has made amendments to certain paragraphs of Article 29.22 A (4), as described below, to clarify some of the high quality criteria of the IRAPS, which are consistent with AAA instructions, which it formulates and promotes labour standards that guarantee the well-being of trainees. The Department has also made amendments to other paragraphs of paragraph 29.22 above to review comments on the relationship between SRS and ADRs they have recognized, on data collection by the Department and SREs, and on the evaluation of results. With respect to the sectoral orientation model provided for by the rule, the Department found that the ABILITY of SRRs to recognize PDOs provides the flexibility to foster more apprenticeship spaces in new industries, while ensuring that learning meets the quality standards set by the department. In addition, this rule deliberately departs from the requirements of the registered apprenticeship program. The Ministry considers IRAPS to be separate from registered learning and registered apprenticeship programs because of the sectoral characteristics of programs defined by the EC and not by the department. Although the department has used some of the characteristics of the registered learning model, it rejects commentators` proposals to model IRAPS based on registered learning programs. On the contrary, as reflected in the discussion that followed on specific sections, the Department has put in place a strict framework for the recognition of SRE and IRAP, while creating the flexibility necessary to enable sectoral innovation. The start Printed Page 14315Department acknowledges commentators` concerns about the possibility of different standards within the industry, but believes that SREs and their industry experts are best placed to set standards that meet the requirements of this rule, in accordance with market conditions. The Department sees differences in standards and programs as an advantage in increasing the competitiveness and benefits of the IRAPS. One commentator argued that the proposed rule does not solve many problems, such as challenges. B employers in terms of navigation in the learning system, lack of attention to reciprocity and uncertainty of trainees regarding the evaluation of program quality. Several commentators suggested that each SRE and IRAP candidate be classified as page 14300 printed at start-up in accordance with the codes of the U.S. Industry Classification System (NAICS) or the Occupational Information Network (O-NET).