Responsible Master's Scope Over Multi-Crew New Construction
You are the Responsible Master Plumber (RMP) for a company running three residential rough-in crews plus a service van on a 60-lot subdivision. The company's certificate of insurance lists you as RMP, and your name and master license number appear on permits for all 60 lots. You visit jobsites roughly twice a month. One crew leader, who holds only a Tradesman Plumber-Limited license, has been directing two apprentices to install gas piping and to pressure-test it without your direct supervision. A municipal inspector fails lot 22 for an improper test and asks who supervised the gas work. The crew leader says you approved the approach by phone. Separately, the service van technician performed a water heater replacement under the company's master license without a permit on a lot outside the subdivision.
1. As RMP, what is your responsibility for the gas piping installed by the limited tradesman and apprentices, and how should you respond to the inspector?
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The RMP is accountable for plumbing work performed under the company's master license, including work by licensees and apprentices operating under that license. Supervision is not satisfied by phone approval of an approach; it requires the RMP to ensure work is performed by appropriately licensed/registered individuals within their scope and to exercise the oversight the rules contemplate.
Key points to state to the inspector:
- Identify yourself as RMP and provide your master license number.
- Acknowledge the gas piping was installed under your company's license.
- A Tradesman Plumber-Limited may not independently direct work outside the scope of that license; gas piping supervision must come from an appropriately licensed master/journeyman.
- The failed test must be corrected and re-inspected; do not argue the phone call as a defense.
Practical fix: assign a qualifying master/journeyman to directly oversee gas work, document supervision, retest lot 22, and review the other lots for the same pattern before more inspections.
2. The unpermitted water heater replacement on the outside lot - whose problem is it and what exposure exists?
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It is the RMP's problem. Work performed under the company's master license is the RMP's responsibility regardless of which technician pulled it. Installing a water heater typically requires a permit, and doing so without one is a code/administrative violation.
Exposure includes:
- The RMP and the company being cited for work without a permit.
- Possible disciplinary action against the master license, since the RMP is the qualifying licensee.
- Liability if the installation fails (TPR discharge, venting, gas connection).
Corrective steps: pull the required permit, have the installation inspected, verify venting/TPR/expansion and gas connections, and put a written policy in place requiring permit checks before any replacement. The RMP cannot delegate away the responsibility by blaming the technician.
3. What supervisory controls should you put in writing to prevent recurrence across all 60 lots?
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A defensible program includes:
- A written scope-of-work matrix showing which license class may perform and supervise which tasks (gas piping, medical gas, water heaters, etc.).
- Named supervision assignments: each crew has a qualifying master/journeyman of record for scope-limited work.
- A permit log tied to lot number, with a pre-work permit check and a closeout inspection before final.
- Documented site visits with dates, findings, and corrections - not just phone approvals.
- Apprentice registration verification and ratio/scope checks.
- A corrective-action log for failed inspections (like lot 22) showing retest results.
The RMP should audit a sample of completed lots against these records and retain them, because the ability to show actual oversight is what protects the license if a complaint is filed.