Multiple Classifications of Contractors Can Waterproof Decks, But Few Have to Pass a Written Proficiency Test

D-12 Synthetic Products Classification Doesn’t Require a Proficiency Test

Manufacturer’s Accept D-12 License’s to Become Authorized Applicators

If you want to be a general contractor, plumber, electrician, earth mover, well driller, roofer.. CSLB requires you to have 3 years certifiable experience in that trade, plus take a legal exam on CSLB and state contracting laws AND pass a 3 hour test on your proficiency in that trade. You have to prove you know what your doing before they give you a license to do it. There’s a risk to consumers from people who don’t know what their doing. CSLB goes out of their way to run sting operations on unlicensed contractors, running press releases and posting hidden videos of their stings.

However, if you want to be a contractor that installs waterproofing for foundation walls and decks, decks like say the balcony in Berkeley, you don’t need a license that has a test that proves you have some knowledge; you can obtain a D-12 Synthetic Products license like this author has. A D-12 Synthetic products contractor does not have to pass a written test of proficiency in the subject of waterproofing! You just need to apply for it if your licensed in another trade and add it to your classifications and start waterproofing decks and foundations as most of the deck manufacturer’s accept the D-12 classification to sell and install their products.

How do I know this? Because I have/had a D12 license classification with which I used it to waterproof decks and balconies. But I’m not the only one, there are many contractors out there waterproofing decks using a D12, as well as using a C8 (concrete) or a C33 painting license improperly apparently, and CSLB seems to have a lassez faire attitude about this issue.

Will CSLB change the licensing requirements for becoming a deck waterproofing contractor?

It’s time for it in my opinion. My further opinion is it’s time for manufacturer’s to stop accepting D12 licenses and require or implement training/education that ensure contractors know what they are doing. My experience as a consultant and former contractor is that nearly every case of a deck failure/leak/problem was a case of applicator or builder error, not the product or coating.

I learned the hard way not to accept conditions that others wanted me to accept so they could keep their project on track. Deck contractors MUST be able to inspect a deck and recognize any problems it might have before covering it or accepting the work. They must know how to properly flash a deck, install door pans, install waterproofing, test for moisture content before covering a deck, follow best building practices and insist any trades related to the deck as well. The training program I’ve personally developed over 8+ years that I use to train new deck waterproofing contractors demands a high degree of technical skill and willingness to exceed codes!

Below from CSLB is a email to me regarding my own situation. I’m using my experience in this opinion piece as it exemplifies the internal issues CSLB has on this. Note that CSLB Used to have a waterproofing classification but it went away. The D-64 Waterproofing also did not require a test either.

Context-a client had complained to CSLB about a deck failure. Part of the complaint was that I was out of class in doing the deck waterproofing using a D12 license. The part of the complaint about the deck failure went to arbitration where it was settled privately and is not subject to disclosure on my license. Part of the complaint did stay with CSLB, the part of license classification. So they went to work on that and I defended myself. Read through to see what CSLB says about their D12 problem.

“Hi Bill,

One of the complaint items provided by Mr X was that your company was operating out of class for the work performed. The arbitration does not address classification as part of its process, so I needed to address this issue separately. As you know, your company holds a D12 (Synthetic Products) classification. This classification is defined as follows:

A synthetic products contractor installs:

• (a) Synthetic counter tops and wall coverings; fiberglass, plastic, vinyl and epoxy products; plastic tile board and decorative art work; and synthetic turf.
• (b) Bathtub and enamel refinishing, resin and epoxy application, and synthetic caulking and sealants.
• (c) Reservoir liners, vinyl swimming pool relining, pier piling wrap, and rodent guards.
• (d) PVC piping systems for irrigation and drainage; subsurface irrigation drip systems.

As you can see from the definition, there is a very limited scope of work for this classification. For Mr. X’s project, as well as the other services listed on your website, the D12 classification is not appropriate. A General Contractor’s license (B) would best suit your business as it would safely encompass all unrelated trades. Short of a B license, there are specific trade classifications that more accurately apply to your services for concrete overlays, deck coatings, etc. You can review the classifications by clicking HERE.

For Mr. X’s case specifically, the work (waterproofing, flashing) performed would have required either a B license or a C39 Roofing classification. The definition for the C39:

A roofing contractor installs products and repairs surfaces that seal, waterproof and weatherproof structures. This work is performed to prevent water or its derivatives, compounds or solids from penetrating such protection and gaining access to material or space beyond. In the course of this work, the contractor examines and/or prepares surfaces and uses the following material: asphaltum, pitch, tar, felt, glass fabric, urethane foam, metal roofing systems, flax, shakes, shingles, roof tile, slate or any other roofing, waterproofing, weatherproofing or membrane material(s) or a combination thereof.

I would recommend reviewing the classifications and either adjust the work you perform to fit the D12 classification or apply for more suitable classifications. The General Contractor (B) classification would be all-inclusive, but you can certainly piece together classifications to fit the work you perform.

Since we don’t have a history of complaint issues with you, I will simply send you a warning letter for this issue. If you have any questions, let me know.

Shaun Baland

Investigator, Sacramento IC CSLB Enforcement

QUESTIONS? YES I HAVE PLENTY!

I was stunned as I had applied to CSLB and stated on my application what I was doing-installing flashings, deck waterproofing and replacing plywood substrate! So I replied to CSLB with this email below

Hi Shaun, Thank you for the information.