Unpermitted Work in a Rental Duplex
R. owns a duplex in unincorporated Pierce County, an L&I electrical jurisdiction. He occupies one unit and rents the other. In March he replaced the 100 A panel in the rented unit, added four branch circuits, and ran a 60 A feeder to a new detached shop in PVC buried 18 in. deep, with the shop fed from the duplex service. The drywall in the rental unit was patched and painted before anyone inspected. The feeder was installed by a neighbor who holds an electrical trainee certificate and who worked alone. No permit was ever pulled. R. is now selling, the buyer's inspector flagged the panel, and R. asks whether he can pull an owner's permit now, sign off on his own work, and simply have L&I do a final.
1. Can R. permit and self-certify this work? Address the owner exemption, the trainee, and the permit requirement.
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No, on all three points.
- Permit. Electrical work requires an electrical permit before installation (RCW 19.28.091 and the local jurisdiction's permit rules). Work performed without a permit is not made lawful by the passage of time; the permit must still be obtained and the work inspected.
- Owner exemption. The exemption for working on one's own property is limited to a single-family residence the owner owns and occupies. A duplex is not a single-family residence, and the rented unit is not owner-occupied in any event. R. cannot self-permit either unit's work.
- The trainee. An electrical trainee may perform electrical work only under the supervision of a certified electrician, and must be employed by a licensed electrical contractor. A trainee working alone on a service change and a feeder is not permitted regardless of whether the work is otherwise correct.
The work must be permitted through a licensed electrical contractor, who takes responsibility for the installation and for verifying what it can of the concealed work.
2. The contractor walks the job. What code defects should be expected, and what has to happen about the concealed drywall?
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Burial depth - the shop feeder. Table 300.5 requires 24 in. of cover for a direct-buried PVC feeder in an ordinary yard location (18 in. applies only under a 4 in. concrete slab or a 2 in. concrete trench cap, and 18 in. also appears in the dwelling driveway/garage row - neither matches this installation). The feeder must be re-dug to 24 in., or a 2 in. concrete cap installed over 18 in. of cover if that option is chosen and permitted locally.
Other likely findings: whether the shop's 125 V receptacles are GFCI protected, whether the detached shop has its own grounding electrode system (250.32), and whether the service change in the rental unit was installed with the correct service conductor ampacity, grounding electrode conductor and bonding.
Concealed work. Electrical work may not be concealed before it is inspected. The patched and painted wall must be opened for the inspector to see the panel, the circuit routing, box fill, conductor protection through framing, and the new feeder's termination. Concealed work that cannot be examined cannot be approved, and the contractor should not represent otherwise. Expect correction notice(s), re-inspection fees, and a schedule in which the drywall repair is done after, not before, the rough inspection.
3. R. says the buyer's inspector 'already looked at it,' so the final inspection is just a formality. What should the contractor tell him, and who can sign what?
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A buyer's home inspection is not an electrical inspection and has no legal effect. Only the electrical inspection authority - L&I, or the local inspection authority where one exists - can approve the work, and only a permit holder on the job can request that inspection.
Who signs what:
- The electrical contractor holds the permit and is responsible for the installation and for corrections; the homeowner cannot sign off on the contractor's work.
- The contractor's responsibility is limited to what it can actually verify. It cannot certify another party's concealed work - that is delivered by opening the walls and by an L&I inspection of the rough-in.
- A final approval covers only work that was inspected at the stages the code and the authority require.
The honest answer to the seller is that the sequence is: licensed contractor, permit, opening of concealed work, rough and final inspections, corrections, then drywall and paint. Any promise of a paperwork-only sign-off is a liability for the contractor and a disclosure problem for the seller.