Duties and responsibilities of the Electrical Contractor Licence holder

Passing the exam is the start of a legal relationship, not the end of one. When the City issues Nadia an A licence, she becomes personally responsible for every permit taken out under it, for as long as those permits stay open. Outside Winnipeg, a Manitoba Hydro ePermits account holder takes on a similar responsibility. And every licence holder in Manitoba carries duties under The Electricians' Licence Act about who may do electrical work and how apprentices are supervised. This lesson collects those duties in one place, using the City's licensing rules, Manitoba Hydro's terms and conditions for permit account holders and the Act itself.

Raymond has carried these duties for more than twenty years, and he is clear with Nadia about what changes when her licence is issued. Today, when she signs a permit application as an authorized signee, the permit is Raymond's responsibility. After she is licensed, any permit she takes out under her own licence is hers, and so is any permit taken out by people she authorizes.

Responsibility for permits under the City licence

The City's licensing page sets out the core rule plainly. A licensed contractor is responsible for all work on permits obtained under the licence, including permits obtained by authorized signees or by an associated company. That responsibility continues even after those people are removed from the licence. A licence holder also remains responsible for active permits after the licence itself expires, until those permits are closed or cancelled. Before a licence expires, the holder needs a plan to close all active permits, or must renew for long enough to finish the projects. Permits cannot be transferred to another contractor.

Each part of that rule has a practical consequence. Because responsibility follows the licence, a licence holder should authorize signees with care and supervise the work done under their permits. Because responsibility survives the removal of a signee, removing someone from the licence does not wipe the slate clean; their open permits still need to be finished and closed. Because responsibility survives the licence's expiry, a licence holder cannot walk away from open jobs by letting the licence lapse. And because permits cannot be transferred, a retiring licence holder cannot simply hand open permits to a successor. The jobs must be finished and closed under the original permits, or cancelled and permitted again according to the City's procedure.

Authorized signees

An authorized signee is a person the licence holder authorizes to take out permits under the licence, usually a supervisor or office manager who handles applications day to day. Signees are convenient, but the City's rules make the licence holder responsible for what they do. The City may also remove an authorized signee who has been disrespectful to staff, or suspend the contractor licence. At each renewal, the licence holder must confirm their own contact information and that of their authorized signees.

Nadia decides to authorize Jasmine, because Jasmine prepares most permit applications, and Luc, because he runs most residential jobs. She writes down what each of them may and may not do: Jasmine may submit applications that Nadia or Luc has approved; Luc may take out permits for residential work up to a set size and must tell Nadia within a day; neither may take out a permit for a job Nadia has not seen. The City does not require that kind of written internal rule, but it is how a careful licence holder manages a responsibility she cannot delegate.

Duties as a Manitoba Hydro account holder

Outside Winnipeg, the person behind Red River Electric's ePermits account has agreed to Manitoba Hydro's terms and conditions for electrical contractors. Those terms make the account holder responsible for the electrical installation covered by all permits issued under the account. The account holder must provide the information Manitoba Hydro needs to issue a permit and pay the fees in the current schedule of electrical permit fees. Work cannot start until the permit has been issued. All work covered by a permit must be completed before the permit expires; if that is not possible, the account holder contacts Manitoba Hydro to request an extension, or gives written notice if the work will not be completed. The work must comply with the current Manitoba Electrical Code, the account holder must notify the inspection department as soon as work is ready for inspection, and wiring defects identified by the inspection department must be corrected immediately.

Duties under The Electricians' Licence Act

Every licence holder in Manitoba also carries duties under the Act. Section 16 forbids employing or engaging anyone to do electrical work unless that person is authorized. For a contractor, that means checking the licence of every person who does electrical work on the company's jobs, including subcontractors and temporary workers, and keeping a record. Section 4.1 requires apprentices and trainees to work under the direct and personal supervision of a qualified licence holder on the same job. Supervision means being there and directing the work, not being available by phone from another site.

Section 17 requires a person doing electrical work to produce a valid licence or permit when an inspector asks, or to prove that they hold one. Doing electrical work without a licence, or breaching the regulations after notice, are offences under the Act, and the Act allows for fines and, on default, imprisonment. The maximum amounts in the Act are modest by modern standards, but a conviction can affect a licence, a contractor's reputation and future work with general contractors and public owners.

Apprenticeship ratios are set separately. The Act states that it does not stop the Apprenticeship and Certification Board from setting apprentice-to-journeyperson ratios. Check the current ratio for the construction electrician trade with Apprenticeship Manitoba before staffing a crew with several apprentices.

Records and communication

None of these duties can be met without records. A licence holder should keep, at a minimum, a list of open permits with their status, the licence numbers of everyone who works under those permits, inspection reports and corrections, and copies of applications and fee receipts. The City's rules also expect the licence holder to keep contact information current, and Manitoba Hydro's terms expect prompt notice when work is ready for inspection or will not be completed. A licence holder who cannot answer the question which permits do I have open and who is working on them has a problem, whatever the state of the wiring.

Good communication with inspectors also matters. Inspectors deal with many contractors, and they remember the ones whose work is ready when requested, whose permits are complete and whose defects are corrected promptly. The City's rules expressly allow it to remove signees who are disrespectful to staff. Courtesy is not a legal technicality, but it is part of running a licence well.

# Section 16 check: is each worker licensed for the task assigned?
SCOPE = {
    "HC": {"power", "lighting", "service", "low-voltage data"},
    "H": {"power", "lighting", "service", "low-voltage data"},
    "M-V": {"low-voltage data"},
    "apprentice": {"power", "lighting", "low-voltage data"},   # only under direct supervision
}
crew = [("Luc", "HC", "service"), ("Agency worker 1", "HC", "power"),
        ("Agency worker 2", "M-V", "power"), ("Ben", "apprentice", "lighting")]
for name, licence, task in crew:
    ok = task in SCOPE.get(licence, set())
    note = "ok" if ok else "NOT COVERED: reassign"
    if ok and licence == "apprentice":
        note = "ok if directly supervised on site"
    print(f"{name:<16} {licence:<11} {task:<17} {note}")

Luc              HC          service           ok
Agency worker 1  HC          power             ok
Agency worker 2  M-V         power             NOT COVERED: reassign
Ben              apprentice  lighting          ok if directly supervised on site

The scope sets in the script are simplified for illustration. Real licence scopes are defined in the ITS bulletin and the regulations, and an apprentice's tasks also depend on their level and the supervising journeyperson's direction.

When something goes wrong under the licence

Sooner or later, a licence holder faces a problem on a permit: a serious defect, a complaint from a customer, a dispute with an inspector or work done by a signee that the licence holder would not have approved. The responsibility rules mean the licence holder cannot step aside. The right response is to deal with it directly: visit the site, find out what happened, correct the work, keep the inspection authority informed and record what was done. If a signee or crew member caused the problem, the licence holder decides whether to change their authority, retrain them or remove them from the licence, remembering that removal does not end responsibility for permits they already took out.

Raymond tells Nadia about the one serious complaint of his career, when a crew he had sent to a small renovation covered wiring before the rough-in inspection. The City required the walls to be opened. Raymond paid for the drywall repair himself, met the homeowner and the inspector on site, and changed the company's procedure so that no crew could request a drywall crew without the site lead confirming the inspection had passed. The licence came through unharmed, and the customer later hired the company again.