Running the maze

September 27, 2023

They gave me an honorary B.S. in Paper Pushing Studies after (a) building compliance software for California HOAs, (b) leading development of two, separate, payment systems, complying, respectively with PA-DSS and NACHA operating guidelines, and then, (c) sponsoring my cofounder's H-1B visa.

When it comes to running a California electrical contractor, I'm not sure my B.S. is enough; that requires compliance with two complex regulatory regimes, for the privilege of wiring outlets.

High construction prices? Speculators and tech bros, naturally. 🤣

DIR

California's Department of Industrial Relations regulates "labor": wage complaints, workplace safety (Cal/OSHA), etc. Importantly, they also administer occupational licensing for electricians.

Per DIR:

Legislation passed in 1999 requiring all electricians who work for a C-10 electrical contractor to be certified by the state of California.

The page goes on to explain that, to work as an electrician, you must be one of three things:

  1. "Certified by having taken and passed the exam", or
  2. "An apprentice in a state approved program", or
  3. "An electrician trainee"

The industry perception seems to be that these rules apply only to "line-voltage" electricians, not folks installing Ethernet, CCTV, or other "low-voltage" applications. I'm not sure about that, but I am increasingly convinced that, despite DIR writing that the requirements apply to "electricians who work for a C-10", (site) they actually apply to anyone (factory, contractor, whatever) doing line-voltage work in California. I looked at jobs (for CSLB experience, below) and found multiple "Required: California Journeyman Certification" for work in factories, which doesn't seem likely if it was just contractor employees who needed the certification.

And of course, it isn't easy to get (certification): (a) a written exam, and (b) between 2,000 to 8,000 hours of work experience, documented by the hour and substantiated by social security payroll records, across 17 categories of work with specific hour requirements, for each category. People (aspiring journeymen) get this experience in one of two ways, detailed below.

I'm enrolled as a trainee: a "do it yourself" path of (a) taking classes at an educational institution of your choice, from a state-approved list of about 100 statewide (in my case, Laney College), and (b) finding an employer who takes trainees, which isn't easy as to remain compliant, each trainee must be supervised by a certified journeyman, who may supervise a maximum of one trainee concurrently. Out of 50+ employers, I've found one willing to do this (accept a trainee).

Overall, I can't recommend this path (trainee). I did it because I needed just one year to get CSLB qualification (see below), but as I've learned more about licensure, I now see I have virtually no chance of achieving journeyman certification without years of full-time work at minimal pay; I don't see any way around this. Two notes if you decide to go this path. One, DIR only accepts mailed forms to enroll as a trainee, the form takes 4-6 weeks to process, and even if they deposit your check, there's no guarantee you've made it, as I found out. So start early, because you have zero chance of getting hired legally without an issued trainee card. Second lesson, getting an ET card requires "proof of enrollment", in the form of a sealed, official letter of enrollment from your institution (prepare to wait another week for that to be prepared); a mere printout of the page showing you're enrolled isn't acceptable, as I found out when I received a letter back home, denying my application. I got the letter and am now waiting, another 4? 6? weeks, for my enrollment, with the sealed verification letter, to process.

The more common path is apprenticeship: a structured program (typically five years, I think due to the DIR experience requirement) combining work experience, of the right type, with classroom training for the exams, and $20-25/hr (2023) pay. Apprenticeships are full-time, so unless you plan to be in school for a decade, apprenticeship plus college isn't happening. There both union- and non-union apprenticeships, but given the incentives—five years at roughly equal pay, no academic way around it, and much more pay working for the union afterwards—it's hard to see why anyone wouldn't just go union. Provided, however, that's even an option: we've got a few "pre-apprentices" in my class at Laney, who the union rejected for one reason or another. My teacher (at Laney) thinks this whole system was created with a lot of input from IBEW and other unions to encourage membership, and I can't say I disagree.

Reviewing:

  1. Doing line-voltage electrical work in California requires following DIR rules;
  2. Getting a DIR journeyman certification takes years of full-time work; and
  3. Most people who get DIR journeyman certification, get it via apprenticeship.

CSLB

I mentioned before that the Contractors State License Board (CSLB) administers trade licensing in California. The key thing to realize, which I learned only months into trying to buy a contractor, is that CSLB regulates contracting, narrowly construed: the business of running an electrician, plumber, roofer—bonding, creditworthiness, insurance—not the labor practices, things like hiring, occupational safety, or for electrical work particularly, who's actually touching the copper.

To review, there are three major requirements to get a contractor's license in California:

  1. Be 18 years old
  2. Pass two exams (law, and trade)
  3. Document the equivalent of four years of "journeyman-level" experience

The CSLB has no consistent definition of journeyman, unlike DIR. This is critical—CSLB establishes experience using a sworn statement of one of seven possible "certifiers", relying on the certifier's statement (and judgment) to establish both (a) the length, and (b) seniority (e.g. journeyman), of the license qualifier's experience. (CSLB performs a more thorough verification of facts for 3% of applications, by law, but my understanding is that the facts are accepted without further verification in 97% of cases. Industry perception is that there's a ton of fraud on these applications, which seems likely.)

Further complicating matters, CSLB will give "credit", determined case-by-case, against the four-year requirement, for:

  • Certain types of military service
  • Completion of an apprenticeship program, or
  • Completion of an academic degree, with more credit given for higher, and more relevant, degrees.

In all cases, however, the license qualifier needs at least one year of documented field experience, which can't be waived.

It's kind of hilarious, when you think about it—CSLB will approve a year of field experience (possibly illegal in the eyes of DIR), letting someone like me (an electrical engineering degree-holder with a lot of hands-on experience), operate a firm, while being simultaneously unable to legally bend conduit, place wire nuts, or do other front-line tasks of an electrical contractor.

We'll see what happens—I have an electrician signing off on my many years of electrical field experience, hopefully good enough for CSLB. If, on the other hand, DIR forces me into an apprenticeship to get more experience because, say, CSLB won't approve three years on my M.S. in Electrical & Computer Engineering, well, I'll probably have to find something else to do.

Unless, that is, I can find some other way to convince DIR to let me work.