California license class C-4 and air to water heat pumps

Teemok

I know the CSLB is the only place to ask for a conclusive answer but that's not that easy. ( California State License Board ) If you're not reporting a violation or checking up on a contractor or are an applicant trying to get a license, there's not an obvious point of contact. In fact there's little there for a licensed contractor but to pay, by snail mail of course.

My understanding is that the C-20 HVAC license and C-36 Plumbers license are the approved classes to install air to water heat pumps in CA. I think mono-blocks only for C-36. CA Plumbers are not allowed to service or install anything over 200,000 BTU input combustible fuel. A C-4 is needed for anything over that size. Seems odd to give C-36 HP water heating approval but not C-4 when water heating is precisely what a C-4 contractor does.

This is the CSLB's C-4 class description from their website:
A boiler, hot-water heating and steam fitting contractor installs, services and repairs power boiler installations, hot-water heating systems and steam fitting, including fire-tube and water-tube steel power boilers and hot-water heating low pressure boilers,steam fitting and piping, fittings, valves, gauges, pumps, radiators, convectors, fuel oil tanks, fuel oil lines, chimneys, flues, heat insulation and all other equipment, including solar heating equipment, associated with these systems.

"And all other equipment ......, associated with these systems." This seems like it might be open language that includes heat pumps.

I'd like to be able to offer my customers permitted air to water heat pumps without debate at the different authorities counters. There's 38.8 million people in California and from my estimating/ guess there's somewhere around 3,500-4,500 C-4 license holders and less that are currently active. Many who have C-4 hold the C-36 as well. Sole C-4 contractors are not a big lobby.

I got my universal EPA certification in 1998 and have done years of service and installation for HVAC contractors. I own all the tools. I have the experience to test for the C-20 license if it comes to that but I don't want to do HVAC or Plumbing for that matter.
Some permit officials have no issues and others, in the next town over, flat out refuse me as heat pumps are not called out specifically in the CSLB C-4 description. Fair enough, they are just trying to be good at their gate keeping jobs. The very same person lets a C-36 install a 400,000 BTU water heater because they can't find anything about a commercial size limit.

One official had no idea what a C-4 license was. He had to look it up and was still confused. He went on to straight face inform me that, his ignorance is good evidence that there are no boilers in his city. Great deduction Watson!

In another case I found a near by C-20 HVAC contractor with "Hydronics" in his legal name installing and servicing boilers and radiant floors with permits. Funny because I had to appeal to CSLB higher up's to convince them a C-4 contractor is by definition a hydronics contractor for them to give approval for "Hydronics" to be in my company name.

It would be just like a bureaucracy to say heat pumps are the future, began to mandate them out of one side of their mouths and then limit the ability of commercial water heating contractors to install them with the other.

Anyone have any knowledge on the topic before I start digging at CSLB? Does your state have a similar C-4 license class? Who's allowed to air to water HP? I'm hoping I've just missed a little known memo that includes C-4 in the water heating heat pumps game.

Larry Weingarten

Hi, I would contact these folks first and see what they have to say. https://switchison.org/about-us/ It's clearly in their interest to have contractors on their side.

Yours, Larry

Teemok

@Larry Weingarten Thanks, I will contact them if this becomes a lobby to correct a wrong. I'm still not sure if there is in fact a wrong or just a failure to update the c-4 description. I don't think I want be a one man crusade if it is really a bad official policy. It would be easier for me to pass the C-20 test vs trying to change CSLB board members minds. I guess I have a letter in me as a community service effort.

DCContrarian

It seems the regulations need to catch up with the technology.

Most air-to-water are sealed units so the installer doesn't have to handle refrigerant.

The ones I've seen are filled with a glycol solution to prevent freezing, so they don't connect to the domestic plumbing. The installer doesn't have to worry about contaminating the water supply.

They don't burn anything so the installer doesn't have to worry about killing the occupants with carbon monoxide, or blowing the house up with leaking fuel.

Really the only things the installer has to worry about is having a pressure release so it can't explode, and not electrocuting anyone. In terms of public safety I'd say it's on a par with installing an electric water heater. So that's the level it should be regulated at.

Mad Dog_2

California Dreamin...San Franciso is probably the Oldest Major City?  Mad Dog 

WMno57

Teemok said:

Does your state have a similar C-4 license class? Who's allowed to air to water HP?

In-depth article here that discusses all kinds of licenses in all 50 states.
https://www.newsnationnow.com/us-news/education/labor-shortage-make-it-easier-to-work/
Even better, within the article there is a link to this 50 state licensing app that has tons of detailed information on 1100 jobs that require State Licensure.
https://app.powerbi.com/view?r=eyJrIjoiNzA0MGM4NGMtN2E5Ny00NDU3LWJiNzMtOWFlMGIyMDczZjg2IiwidCI6IjM4MmZiOGIwLTRkYzMtNDEwNy04MGJkLTM1OTViMjQzMmZhZSIsImMiOjZ9&pageName=ReportSection
The App is hot linked in the blue text "are among 15 states" found here:

Over 1,100 jobs are regulated in at least one state, but fewer than 60 are regulated in all 50 states.

Illinois and Pennsylvania are among 15 states where HVAC contractors don’t need a state license to work. Most others require a credential that comes after years of experience and a professional exam.

Regarding the 50 state licensing app, I'm not sure of the source. It may have some errors.

Teemok

@DCContrarian You are describing the simplicity of a mono-block HP. Buffer tanks, pipe sizing, pumping and glycol make it a little more complicated than an EWH. Agreed, it's not hard.

@Mad Dog_2 San Diego apparently by the spanish 1769. What counts as a city? Gold 1849 made for rapid wild west growth.

DCContrarian

Teemok said:

@DCContrarian You are describing the simplicity of a mono-block HP. Buffer tanks, pipe sizing, pumping and glycol make it a little more complicated than an EWH. Agreed, it's not hard.

So this is a debate I've been having with some of my friends recently: Should codes enforce comfort, quality and consumer protection, or just safety? Is it the inspector's role to ensure that a heating system or water heater is an appropriate selection, or just not capable of killing the occupants of the house?

Because screwing up the buffer tank, piping, etc. doesn't endanger anyone, you just end up with a system that doesn't work.

pecmsg

Codes are Minimum Standards!

Teemok

I have little problem with code or inspectors. I believe code is for more than just avoiding danger. It seeks a minimum quality and is also the primary recourse for insurance companies to avoid future payouts. Professional liability is on the designer whoever that might be. Inspectors look to equipment manufactures as they hold liability for equipment design, its intended use and installation requirements. Inspectors can't be designers or engineers but they have final authority and judgment on what passes as minimum standard in their jurisdiction.
I'm dealing with an administrative policy question. The licensing board chooses what class of license is appropriate to be able to pull a permit to do what kind of work. The standard plumber has been given approval to install air to water heat pumps but the higher level commercial water heating specialist pipe fitter seems to be left out of the electric water heating game. I can't think of a logical reason for it. It's likely just a missed detail of bureaucracy in a changing world.

WMno57

Per the article and app I linked:
Illinois, Pennsylvania, and New York are among 15 states where HVAC contractors don’t need a state license to work. Some cities / counties in these states may have their own licenses. Most places have codes and permits.
Green - License Required. Red - No State Licensing.
Are these maps correct?

HVAC Contractor


Journeyman Plumber

Teemok

@WMno57 First, thanks for trying to help. I'm already a California licensed contractor class C-4 (200k+BTU input boilers, water heating, hydronics, steam fitting.) I know the licensing requirements of my state. The issue is about what kind of license class is approved to pull a permit to install an air to water heat pump. I thought I explained it well above.

Teemok

I was kindly guided to the correct email contact at the CSLB to ask about this. The Licensing classification deputy confirmed that C-20 HVAC and C-36 Plumbers are in fact the only license classes authorized to install water heating heat pumps. I wrote explaining that I think excluding the license class that's existence is centered around heating water is a oversight. I requested explanation or help with correction.

Got a responds! My email was forwarded to the executive office, it being reviewed and a responds is being worked on. Hope for the triumph of logic with authority is a precarious position. Maybe the gears are moving, I'm hoping for the best.

Steamhead

It's important to note that if a state does not license this at the state level, it might be licensed at county or municipal levels. A while back, there was a push to move licensing in Pennsylvania to the state level, or at least to make things consistent across jurisdictions, but I'm not sure if anything came of it. @Dave Yates (GrandPAH) was involved with that- some of his contributions are here and here.

BTW Dave- heard from "Tickles" lately? 🤣

Maryland has state licensing, but most counties and a lot of municipalities have their own permitting, licensing and inspections as well. And they don't all reciprocate. It remains a fair question as to what good all these licensing layers do, except generate revenue, and with Maryland being a leader in political corruption………

Edit- @Erin Holohan Haskell , seems these older HH links don't post properly………..

Teemok

@Steamhead California definitely licenses it and like many places it is locally enforced at the town, city, county and sales level. What type of license is approved to install and repair is determined by the CSLB. They are reviewing my appeal to reason now. I was expecting: "Get lost, It's too small a problem to address. The C-4 license is a carbon and solar classification only. Sorry for the inconvenience. Get yourself one of the approved classifications if you want be involved with the heat pump water heating future." But no……."We are considering your argument" is way better than that. I've really got no problem with inspectors beyond the standard power position ego hassles that occasionally happen. ABC, always be cool, works most of the time.

Erin Holohan Haskell

@Steamhead I've created hyperlinks for you above.

Teemok

Got a boiler plate response from the same CSLB deputy that says you can stand and pitch your case for 3 mins at a board meeting where they will not respond and have no obligation to ever respond. No other comment from the deputy of classifications at all. Basically a robot thank you for contacting us, now go away. I'm not convinced my case was ever sent to anyone with any power. It's a two hour drive. It might be fun to deliver a pitch just to see the body language and know I did all I could. It's probably for the better to just get my HVAC classification anyway. Lawyers are likely the only real way to get any attention to change anything.

EBEBRATT-Ed

Maps are not right. CT requires licensing for everything. Alarm systems, Installing TV antennas HVAC, PLUMBING ELECTRICAL gas etc. sheet metal etc

MA is pretty much the same except no refrigeration license required under 5 tons (I think) used to be 10 tons. You just need your EPA license.

Both are statewide permits

GGross

https://forum.heatinghelp.com/discussion/comment/1806102#Comment_1806102

I think the 3 minutes and no comment is pretty standard for local and state government boards that accept open public comment. You can imagine that if someone were to show up to one of these and board members appear to "argue" with the commenter things can go out of order really quick . Many such boards offer the opportunity to write or email a written comment to be read aloud at their meeting. That may be a better solution than spending the drive time. I would imagine your comment time won't get any sort of immediate action, but it is possible it might bring the possibility of an issue to the boards attention and at least get them thinking about it. If you want true and earnest discussion you would need to get your specific issue posted on their agenda and I am not sure how you could do that

Teemok

@GGross I came to the same conclusion after the disappointment dissipated. I surprised myself with the disappointment. Otherwise known by it's precursor: expectations. I know better. I'll give a friendly and persuasive pitch and maybe I'll get some feed back, maybe I won't but I'll have made the effort the proper way. You can try a bunch of ways to make something happen but your a fool if you don't try the one way it's supposed to work.