In California, can a HVAC technician replace the unit's electrical disconnect?

[mtnelect]

This Forum should not only deal with building codes but also needs a new category added to the list "State Contractors License Boards". This will help educate contractors on license laws in other states.
1) How to get a contractor's license in other states.
2) Contractor's license laws in other states.
3) How to treat consumers lawfully.

 

[tortuga]

For a C-46 or even a C-20 it might hinge on whether the service upgrade is necessary to perform the other work. But jurisdictions who care, and the CSLB, are not likely to look kindly on that argument.

Yeah I bet they might, and jurisdictions should be aware that a C20 or C46 can replace a electrical service with no additional license if its related to their work.
I just wanted to clarify what the law says today in 2024, not what it should say or what everyone thinks it says or what I think it should say.
All the C10 license does is add more regulations and restrictions to the work a C20 or C46 is already legally allowed to do.

 

[ramsy]

All the C10 license does is add more regulations and restrictions to the work

Is that the JW card requirement for employees, which no other trade needs to do electrical?

 

[mtnelect]

It has almost no Enforcement other than guys trying to get their license and the oddball perfect case

Since the CSLB (Contractors State License Board) has limited staff, it only comes into play when a complaint is filed.

 

[tortuga]

Is that the JW card requirement for employees, which no other trade needs to do electrical?

Yeah my thought is as soon as your a C10 then none of your employees can touch electrical unless they are certified.
So for a C10 replacing a 24V thermostat, replacing the disconnect, compressor motor etc... would technically have to be done by a certified JW.
But if they are a C20 no such requirement as long as the electrical work is related to HVAC.
I am not sure what the C20 test is like if its like, one would think it includes questions on motors, compressors and electrical code?
I also have never seen a C46 or whatever the solar test is, but I'd imagine that also would have an electrical section?

 

[mtnelect]

Yeah I bet they might, and jurisdictions should be aware that a C20 or C46 can replace a electrical service with no additional license if its related to their work.
I just wanted to clarify what the law says today in 2024, not what it should say or what everyone thinks it says or what I think it should say.
All the C10 license does is add more regulations and restrictions to the work a C20 or C46 is already legally allowed to do.

One restriction the CSLB is working on .... is the Solar Contractors being restricted to 80KW BBS (Battery Backup Systems) anything larger will require an Electrical Contractor.

 

[roger]

This Forum should not only deal with building codes but also needs a new category added to the list "State Contractors License Boards". This will help educate contractors on license laws in other states.
1) How to get a contractor's license in other states.
2) Contractor's license laws in other states.
3) How to treat consumers lawfully.

Well maybe you should look around the Mike Holt site.

Electrical licensing, exam, and renewal information.

Mike Holt worked his way up through the electrical trade from apprentice electrician through electrical contractor, to become one of the most recognized experts in the world as it relates to electrical power installations. He was a Journeyman Electrician, Master Electrician, and Electrical...

www.mikeholt.com

 

[mtnelect]

Yeah my thought is as soon as your a C10 then none of your employees can touch electrical unless they are certified.
So for a C10 replacing a 24V thermostat, replacing the disconnect, compressor motor etc... would technically have to be done by a certified JW.
But if they are a C20 no such requirement as long as the electrical work is related to HVAC.
I am not sure what the C20 test is like if its like, one would think it includes questions on motors, compressors and electrical code?
I also have never seen a C46 or whatever the solar test is, but I'd imagine that also would have an electrical section?

I requested an interpretation from the CSLB

 

[tortuga]

I requested an interpretation from the CSLB

For example a C-20 outfit (with no C-10) contracted to convert a multi family apartment building from natural gas wall units to high efficiency ductless heaptumps and all the units have 30A electrical panels. A load calculation calls for 60A feeders and a new loadcenter in each dwelling unit and an upgrade to the main electrical service so there is safe capacity for the heat pumps, a C-10 license is not required and the electrician employees of the C-20 HVAC contractor can perform this work without needing to be certified under California Labor Code § 108.4 as there is no way to accomplish this scope of work without the electrical service upgrade, that is what incidental means.

Another example in a more rural area; a consumer wants to ditch the over priced propane delivery racket and switch to heatpump with resistive electric backup, but they have a old 60A service, the C-20 can permit and install a 200A service, as it is incidental and supplemental to that scope of work to replace the electrical service. The scope of work could not happen without the service upgrade, that again is what incidental means.

Now if the customer says while your guys are here working in the attic can you add some recessed lights in the living room? -- Probably not incidental or supplemental so C-10 required.

 

[mtnelect]

For example a C-20 outfit (with no C-10) contracted to convert a multi family apartment building from natural gas wall units to high efficiency ductless heaptumps and all the units have 30A electrical panels. A load calculation calls for 60A feeders and a new loadcenter in each dwelling unit and an upgrade to the main electrical service so there is safe capacity for the heat pumps, a C-10 license is not required and the electrician employees of the C-20 HVAC contractor can perform this work without needing to be certified under California Labor Code § 108.4 as there is no way to accomplish this scope of work without the electrical service upgrade, that is what incidental means.

Another example in a more rural area; a consumer wants to ditch the over priced propane delivery racket and switch to heatpump with resistive electric backup, but they have a old 60A service, the C-20 can permit and install a 200A service, as it is incidental and supplemental to that scope of work to replace the electrical service. The scope of work could not happen without the service upgrade, that again is what incidental means.

Now if the customer says while your guys are here working in the attic can you add some recessed lights in the living room? -- Probably not incidental or supplemental so C-10 required.

This might help to explain.

 

[Seven-Delta-FortyOne]

For example a C-20 outfit (with no C-10) contracted to convert a multi family apartment building from natural gas wall units to high efficiency ductless heaptumps and all the units have 30A electrical panels. A load calculation calls for 60A feeders and a new loadcenter in each dwelling unit and an upgrade to the main electrical service so there is safe capacity for the heat pumps, a C-10 license is not required and the electrician employees of the C-20 HVAC contractor can perform this work without needing to be certified under California Labor Code § 108.4 as there is no way to accomplish this scope of work without the electrical service upgrade, that is what incidental means.

Another example in a more rural area; a consumer wants to ditch the over priced propane delivery racket and switch to heatpump with resistive electric backup, but they have a old 60A service, the C-20 can permit and install a 200A service, as it is incidental and supplemental to that scope of work to replace the electrical service. The scope of work could not happen without the service upgrade, that again is what incidental means.

Now if the customer says while your guys are here working in the attic can you add some recessed lights in the living room? -- Probably not incidental or supplemental so C-10 required.

I do not believe you are correct on that.

Most AHJs definition of incidental would be much more limited than that. Just because another scope is required for a certain project, does not mean the specialty contractor can self-perform that work.

The fact that a drywaller needs a frame to attach his drywall to, does not make him eligible to take on a framing contract.

On these PW jobs I bid, it clearly delineates between what is the Division 23 and 26 respective SOWs, and the EC is required to perform all the wiring for the HVAC system.

At least in my area, the AHJ would not issue a permit to an HVAC contractor to upgrade from a 60A to a 200A panel, because the HO was upgrading to heat pumps. They would require an EC to pull the permit for that Scope.

 

[tortuga]

I do not believe you are correct on that.

Most AHJs definition of incidental would be much more limited than that. Just because another scope is required for a certain project, does not mean the specialty contractor can self-perform that work.

The fact that a drywaller needs a frame to attach his drywall to, does not make him eligible to take on a framing contract.

Ok yeah fair enough, I find the wording of the law to be different from how its been interpreted and enforced, there must either be another California statute I missed or the C-20's have not challenged it.

 

[tortuga]

So back to the OP question about replacing the disconnect as soon as your registered as a C-10 and a C-20 or any classification other than C-7 or C-45 then any employees "who engage in the connection of electrical devices (the definition of "electricians in CA)" 100 volt-amperes and up need to be certified.

In the case of the OP if the contractor is just a C-20 the tech can run the branch circuit, install the disconnect and wire the heatpump without any additional certification, however as soon as the contractor is a C-10 and C-20 then you need a fully certified electrician to run the circuit, install the disconnect etc.

 

[mtnelect]

All persons doing work as an Electrician must be certified by the State of California, but enforcement is another story. At this time the CSLB (Contractors State License Board) doesn't have the staff. The only time this would be enforced is when a complaint is filed, or SWIFT (State Wide Investigative Fraud Team) is involved.

Also, the so called "Loophole" for General Contractors still applies. Any employee of the General Contractor who does work as an Electrician must also be Certified by the Division of Industrial Safety.

 

[tortuga]

All persons doing work as an Electrician must be certified by the State of California

Interesting what makes you think that ? Did California Code, Labor Code - LAB § 108.2(b)(1) change?

(b) (1) Certification is required only for those persons who perform work as electricians for contractors licensed as class C-10 electrical contractors under the Contractors’ State License Board Rules and Regulations.

 

[mtnelect]

Interesting what makes you think that ? Did California Code, Labor Code - LAB § 108.2(b)(1) change?

I forgot to enter the word "Proposed". The CSLB understands the "Loophole" and is working on a sponsor to introduce a bill to correct it.

Also, one restriction the CSLB is working on .... is the Solar Contractors being restricted to 80KW BBS (Battery Backup Systems) anything larger will require an Electrical Contractor.

 

[gene6]

This state needs less regulation, not more.

I think that sums it up quite well.