BILL ANALYSIS                                                                                                                                                                                                    







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       |Hearing Date:April 27, 2009    |Bill No:SB                            |
       |                               |405                                   |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS
                               AND ECONOMIC DEVELOPMENT
                         Senator Gloria Negrete McLeod, Chair

                         Bill No:        SB 405Author:Cogdill
                    As Amended:  April 16, 2009        Fiscal:Yes

       
       SUBJECT:   Contractors:  fire sprinkler installation.
       
       SUMMARY:  Requires any commercial or residential fire sprinkler  
       installation project performed by a Class C-16 fire protection  
       contractor to be under the direct and immediate supervision of a  
       commercial fire sprinkler supervisor or a residential fire sprinkler  
       supervisor.  Also requires fire protection contractors to implement a  
       fire sprinkler installation training program for their sprinkler  
       fitters and supervisors with specified exemptions.  Requires  
       contractors to file a description of this training program with the  
       State Fire Marshal and upon request by state or local fire authorities,  
       requires the contractor to show proof that the contractor's sprinkler  
       fitters and supervisors have received training.  States that a  
       violation of these provisions could be subject to disciplinary action.

       Existing law:

       1)Provides for the licensing and regulation of the State's 250,000  
         contractors by the Contractors' State License Board (CSLB), and  
         authorizes the board to institute disciplinary actions for a  
         violation thereof. 

       2)Provides for specialty classifications within the contracting  
         business, including the C-16 fire protection classification.

       3)Prohibits a general contractor from contracting for any project that  
         includes a C-16 fire protection classification unless he or she holds  
         that license classification or subcontracts with an appropriately  
         licensed contractor.

       4)Requires the installation of a fire protection system to be performed  





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         only by a contractor holding a fire protection contractor  
         classification.  

       5)Does not mandate a system of training or supervision for individual  
         fire sprinkler installers who work under a licensed fire protection  
         contractor.


       This bill:
       
       1)Defines the following terms:

          a)   "Direct and immediate supervision" means to be physically on  
            the project site while supervising others.

          b)   "Sprinkler fitter" means a person, other than an apprentice  
            defined as specified in the Labor Code or tradesperson, who  
            performs work on a fire sprinkler system.

          c)   "Tradesperson" means a person employed by a fire protection  
            contractor to assist a sprinkler fitter or an apprentice defined  
            as specified in the Labor Code with the installation of a fire  
            sprinkler system.

          d)   "Residential system" means a fire sprinkler system subject to  
            the NFPA 13D Standard for the Sprinkler Systems in One- and  
            Two-Family Dwellings, Townhomes and Manufactured Homes as  
            published by the National Fire Protection Association.

          e)   "Commercial fire sprinkler supervisor" means any of the  
            following:

            i)     A person holding a journey worker certification from a  
              state or federal apprentice training program or other state or  
              federal training program of not less than 7,000 hours for the  
              trade of fire sprinkler fitting.

            ii)    A person with verifiable work experience of at least 7,000  
              hours of fire sprinkler installations and passage of any  
              examination offered pursuant to a program described in this  
              bill.

            iii)   A person named on a Class C-16 fire protection contractor  
              license.

          f)   "Residential fire sprinkler supervisor" means any of the  





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            following:

            i)     A person holding a journey worker certification from a  
              state or federal apprentice training program or other state or  
              federal training program of not less than 4,000 hours for the  
              trade of fire sprinkler fitting.

            ii)    A person with verifiable work experience of at least 4,000  
              hours of residential system fire sprinkler installations and  
              passage of any examination offered pursuant to a program  
              described in this bill.

            iii)   A person named on a Class C-16 fire protection contractor  
              license.

          g)   "Fire protection contractor" means a contractor licensed by the  
            state as a Class C-16 fire protection contractor as defined in  
            CSLB regulations (Section 832, 16 of Title 16 of the California  
            Code of Regulations).

       2)Requires any commercial fire sprinkler installation project performed  
         by a fire protection contractor pursuant to the Business and  
         Professions Code (BPC) to be under the direct and immediate  
         supervision of a commercial fire sprinkler supervisor.

       3)Requires any residential system fire sprinkler installation project  
         performed by a fire protection contractor pursuant to the BPC to be  
         under the direct and immediate supervision of a commercial fire  
         sprinkler supervisor or a residential fire sprinkler supervisor.

       4)Requires every fire protection contractor to implement and maintain a  
         fire sprinkler installation training program, and ensure that every  
         sprinkler fitter and supervisor employed by the contractor attends  
         and passes a training program and examination.

       5)Establishes the structure of the training program to consist of, at a  
         minimum, all of the following:

          a)   Identification of the entity, organization, or person  
            responsible for implementing the training program.

          b)   The employer's system for identifying the necessary skills for  
            the installation of fire protection systems in accordance with all  
            applicable standards for the installation in residential,  
            commercial, and industrial environments.






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          c)   An objective basis for the measurement of the knowledge and  
            skill level associated with the installation of fire protection  
            systems.

          d)   For a commercial fire sprinkler fitter, training shall be at  
            least 7,000 hours of combined classroom and on-the-job training.

          e)   For a residential fire sprinkler fitter, training shall be at  
            least 4,000 hours of combined classroom and on-the-job training.

       6)Recognizes any sprinkler fitter and supervisor who has passed any  
         state approved or federally approved apprenticeship training program  
         in fire sprinkler installation or other similar program of a  
         recognized or accredited school for vocational training as having  
         satisfied the requirements of the fire sprinkler installation  
         training program.

       7)Recognizes any sprinkler fitter who is currently enrolled in, or who  
         has successfully graduated from, an apprenticeship or training  
         program in fire sprinkler fitting approved by any state or the United  
         States Department of Labor as having satisfied the requirements of  
         the fire sprinkler installation training program.

       8)Requires every fire protection contractor to file electronically or  
         on paper a description of his or her training program with the State  
         Fire Marshal.

       9)Requires a contractor, upon request by state or local fire  
         authorities, to show proof of employee training, and would provide  
         that a violation of these provisions by a contractor is grounds for  
         disciplinary action.

       10)Establishes uniform force and effect of this statute throughout the  
         state and prohibits a city, county, or city and county from enacting  
         an order, ordinance, rule, or regulation requiring a person or  
         organization to obtain a certificate of registration or license from  
         the city or county or city and county for sprinkler installation.

       11)Exempts the following from the provisions put forth by this bill:

          a)   A person or organization that only sells or supplies products  
            or materials to a contractor.

          b)   The installation or servicing of special agent fire suppression  
            systems installed in compliance with the National Fire Protection  
            Association's standards for the installation of those fire  





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            suppression systems.

          c)   Inspection activities conducted as part of an insurance or  
            engineering survey.

          d)   Inspection activities performed by a government official as  
            part of code enforcement activities.

          e)   Routine observation of the condition of fire sprinkler  
            equipment by the maintenance staff of an owner or tenant,  
            excluding mandatory five-year tests and certifications.

       12) Establishes that no provision of this bill is deemed to limit or  
         restrict the practice of engineering by licensed or certified  
         professional engineers.

       13) Makes the provisions of this bill operative on January 1, 2011.


       FISCAL EFFECT:  Unknown.  This bill has been keyed "fiscal" by  
       Legislative Counsel.

       COMMENTS:
       
       1.Purpose.  According to the Sponsor,  California Chapters of the  
         American Fire Sprinkler Association  , the purpose of this bill is to  
         set minimum standards for the training and supervision of fire  
         sprinkler fitters.  Changes in building standards are likely to lead  
         to an increase in the number of people employed in the fire sprinkler  
         installation industry.  Currently there is no law in place to ensure  
         that the systems are installed in a manner that will enhance the  
         safety of those who reside and work in buildings that are fitted with  
         these systems. 

         The Sponsor asserts that while it is unnecessary and impractical to  
         license very person who works in the industry, requiring fire  
         protection contractors to develop training and supervision programs  
         will help ensure that fire sprinkler systems are installed properly.   


       2.Background.  The adoption of amendment RB64-07/08 to the  
         International Residential Code (IRC) by the International Code  
         Council in Minneapolis, MN, on September 21, 2008, mandates the  
         installation of fire sprinklers in all one and two family residential  
         dwellings and townhouses effective January 1, 2011.  As a result of  
         this action, it is likely that local jurisdictions will adopt similar  





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         standards in the coming 6 years. 

         Although its impact will not be realized immediately, the next 2 to 5  
         years will see substantial growth in the sprinkler industry as  
         jurisdictions adopt and enforce the 2009 edition of the IRC.

         Recent research suggests that (based on the 40 year average of  
         completed single family dwelling) the residential fire sprinkler  
         industry will require an additional 2,700 layout technicians, 7,100  
         installers, and more that 1,300 Authority Having Jurisdiction (AHJ)  
         plan reviewers and inspectors to do the work.  Fortunately, all  
         11,100 positions will not be needed at the outset but the industry  
         must begin recruiting and training now to meet the demand as it  
         develops.

       3.Arguments in Support.  The  Association of Builders and Contractors of  
         California  believes that the approach taken in this measure would  
         help to ensure all fire sprinkler fitters are either qualified to be  
         supervisors or getting the necessary training needed to become  
         supervisors.  The provisions of the bill are also said to establish  
         regulation of fire sprinkler fitters without unnecessarily  
         restricting entry to the trade or employment in the trade.

         Citing that there are currently over 2,000 licensed fire sprinkler  
         contractors in California,  SHASTA Fire Protection Inc.  states that  
         "not all of these contractors participate in a recognized program of  
         apprenticeship or continuing education for their employees."  They  
         argue that while individual licensing of every fitter employed in the  
         installation of fire systems would be impractical and of significant  
         cost to the state, it is important to public safety and consumers of  
         fire protection systems to expect that licensed fire sprinkler  
         contractors provide appropriate training and supervision of their  
         employees.  SHASTA believes that this bill establishes minimum  
         supervision and training requirements for fire sprinkler contractors  
         (C-16) and that it would ensure that the fire sprinkler industry is  
         adequately prepared for the increase in work resulting from  
         residential sprinkler requirements and that the industry takes  
         responsibility for mandating training and supervision for fire  
         sprinkler fitters. 

       4.Arguments in Opposition.  The  Sprinkler Fitter Association of  
         California (SFAC)  and the  California State Pipe Trades Council  argue  
         that fire sprinklers save lives and property only if they work  
         properly when they are needed.  According to these parties, this bill  
         places the responsibility of certification on the CSLB, which is  
         established and designed to respond to and to investigate complaints  





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         brought forth to it by various methods, mainly citizen complaints.   
         Moreover, because regular inspection of fire sprinkler systems at  
         various intervals during their installation process are required to  
         ensure that these life safety systems operate properly during a  
         critical time when they are needed, the task requires a local agency  
         equipped to ensure compliance with applicable codes and installer  
         qualifications.  The opposition holds that the bill fails to  
         recognize this fact because it neglects to provide an inspection  
         component.  Moreover, for a number of reasons the bill is also  
         thought to leave too much authority with the industry instead of  
         government.  

         The SFAC and California State Pipe Trades Council identified the  
         following deficiencies in the bill: 

                  Applies only to fire sprinklers, and not to specialized  
              fire suppression systems, such as dry chemical systems, etc.

                  Only requires the sprinkler fitter to pass any examination  
              of any training program.  Does not specify the type of  
              examination, and does not require a state examination to  
              determine actual knowledge of California laws and regulations,  
              only that the fitter pass some examination. 

                  Permits the fitter to attend and complete state-approved  
              training programs of other states, but does not require the  
              graduate to take and pass a State of California approved  
              examination to determine if the fitter has sufficient knowledge  
              to install sprinkler safety life systems.

                  Does not require standardized certification or permit to  
              determine who is, and who is not a "competent fire sprinkler  
              supervisor".  The bill states that upon request by the local  
              fire authority, the sprinkler contractor shall verify that his  
              or her onsite employees are trained pursuant to the requirements  
              set forth in the measure.  However, without the requirement of  
              an identification card makes it discretionary for the  
              contractor, in that they can use any method they choose to  
              fulfill this requirement, placing the burden on the local fire  
              authority to determine if the onsite fitters have adequate  
              training.  The contractor can essentially "dump" a bunch of  
              certificates and what not on the lap of the fire authority.   
              This lack of uniformity places a significant burden on already  
              case strapped local fire agencies.

                  Prohibits local authorities from adopting more stringent  





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              standards.

                  Contains no provisions for continuing education to ensure  
              that those who install fire sprinklers have knowledge of current  
              standards.

                  Does not contain a specified number of hours for classroom  
              training.

                  Has the potential to permit over 1500 different training  
              programs.

                  Requires the C-16 contractor to file his or her training  
              program with the Fire Marshal; however, requires nothing  
              further.  The State Fire Marshal must merely accept any program  
              submitted.  Nor does SB 405 specify any funding for the State  
              Fire Marshal to maintain this newly added responsibility. 

         According to the  California Labor Federation  , "California, like many  
         states does not currently require that all fire sprinkler installers  
         have proper training to undertake such work.  Rather than requiring a  
         uniform qualification standard for all fire sprinkler fitters, this  
         measure would allow a patchwork of programs, standards, and  
         certifications to proliferate across California.  Without an adequate  
         and uniformly applied minimum qualification standard, any  
         "certification" is meaningless.  Moreover, the legislation would  
         prohibit local bodies from adopting more stringent standards,  
         preventing them from implementing rigorous guidelines even within  
         their own jurisdictions."

       1.Oppose Unless Amended.  The  Contractors State License Board  (CLSB)  
         believes that this bill assigns a regulatory responsibility to CSLB  
         that is incompatible with current operations, and for which the  
         agency does not have adequate resources or expertise.  More  
         specifically, existing law requires CSLB operations to regulate  
         contractor activities that are more directly related to consumer  
         protection through the contractor-consumer relationship, such as:

                  Determining if a contractor has violated workmanship  
              standards.

                  Determining contractor compliance with architectural  
              plans and specifications.

                  Contractor compliance with contract obligations.






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         Although the Contractors' State License law authorizes CSLB to  
         discipline contractors who do not comply with state laws that govern  
         the employer-employee relationship (Labor Code violations).  Such  
         disciplinary actions against contractors by the CSLB are based on the  
         findings of the appropriate labor agencies (Division of Industrial  
         Relations, Employment Development Department, etc.).  It is on the  
         grounds of this apparent incompliance with existing law to that point  
         that the CSLB opposes this measure and seeks its amendment.

       1.Related Legislation.   AB 660  (Toricco) would require the State Fire  
         Marshall to certify anyone who installs or modifies an automatic fire  
         extinguishing system.  That bill has been double referred to the  
         Assembly Committee on Governmental Organization, and the Assembly  
         Committee on Business and Professions, and is awaiting hearing.

        AB 2288  (Torrico, 2008) would have required the State Fire Marshall to  
         certify anyone who installs or modifies an automatic fire  
         extinguishing system.  The measure was vetoed by the Governor.


       SUPPORT AND OPPOSITION:
       
        Support:   
         
       California Chapters of the American Fire Sprinkler Association  
       (Sponsor)
       Association of Builders and Contractors of California 
       Automatic Fire Sprinklers, Inc.
       California Association of Life Safety and Fire Equipment (CALSAFE)
       FireMaster: Master Protection Corporation
       SHASTA Fire Protection, Inc.

        Opposition:  

       California Labor Federation
       California Professional Firefighters
       California State Pipe Trades Council
       Fire Sprinkler Advisory Board
       Sprinkler Fitter Association of California
        
       Opposition Unless Amended:
        
       Contractors State License Board  (Expressed willingness to work  
       with Author and Sponsor to draft amendments that will bring the  
       bill more in line with existing law.)






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       Consultant:Yuliya Zeynalova