Unlicensed Helper Performing Verification
A licensed fire alarm contractor in Arkansas sends a two-person crew to a new assisted-living facility for final acceptance testing. The crew lead holds the appropriate license. The second worker is an apprentice who has been with the company for eight months and has no individual license. During the inspection, the AHJ observes the apprentice alone at the FACP performing device verification and recording results on the acceptance test form while the licensed lead is on another floor pulling cable. The contractor states the apprentice is 'under supervision' and that the company's license covers all employees' work. The AHJ must decide whether to accept the test documentation and whether to cite the contractor.
1. Does the company license automatically authorize an unlicensed employee to independently perform and document acceptance testing? Explain.
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No. A contractor license authorizes the business to perform work, but it does not convert every employee into a qualified individual for activities that the rules reserve to licensed or otherwise qualified personnel. Acceptance testing and verification involve judgment about device performance, code compliance, and documentation; performing these alone and signing off on results generally requires the individual to hold the appropriate license or to be directly supervised by a licensed person who is present and responsible. The apprentice working alone at the FACP while the lead is elsewhere is not meaningful supervision. The AHJ should not accept test documentation produced by an unsupervised unlicensed worker and may cite the contractor for permitting unqualified personnel to perform regulated work.
2. What should the AHJ require before accepting the acceptance test results?
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The AHJ should require that the acceptance test be performed with the licensed individual present and directly overseeing the work, and that the documentation be signed by the responsible licensed person. The test should be repeated or witnessed for the portions the apprentice performed alone, so the results reflect qualified work. The contractor should provide evidence of the license status of the personnel performing and certifying the test. If the rules require individual certification for verification, the contractor must supply it. Only after a properly supervised and documented retest should the AHJ accept the results; the earlier unsupervised documentation should be set aside.