1.5 Direct Supervision, Ratios & Licensing Exemptions
Key Takeaways
Minn. Stat. 326B.33, subd. 12 limits a licensed individual to supervising two unlicensed individuals, or three for technology circuits or systems work.
Direct supervision under Minn. Stat. 326B.31, subd. 16 requires the licensed individual to be physically present and immediately available during the entire working day; electronic supervision does not qualify.
The licensed supervisor and the unlicensed worker must be employed by the same employer, and the supervisor is responsible for the work's compliance.
An owner may wire a residential dwelling they own and occupy, or will occupy, without a license only if it has a separate electrical utility service not shared with another dwelling.
Unlicensed individuals may not supervise electrical work or assign electrical work to other unlicensed individuals.
Why supervision is tested
Supervision rules decide whether a job site is legal and whether an apprentice's hours count. They come from two places in the exam booklet: the definition of direct supervision in Minn. Stat. 326B.31, subdivision 16, and the duties of licensed and unlicensed individuals in 326B.33, subdivision 12. Expect questions on the ratio, physical presence, same-employer rules, and who is responsible for the work.
What "direct supervision" means
Subdivision 16 lists six conditions. All must be met:
- The unlicensed individual is supervised by an individual licensed to perform the electrical work being supervised.
- During the entire working day of the unlicensed individual, the licensed individual is physically present at the location where the work is being done and immediately available.
- The licensed individual is physically present and immediately available at all times for assistance and direction.
- Electronic supervision does not meet the requirement of physically present and immediately available.
- The licensed individual reviews the work performed by the unlicensed individual before it is operated.
- The licensed individual is able to and does determine that all the work complies with section 326B.35.
The subdivision ends with a liability rule: the licensed individual is responsible for the compliance of all electrical work performed by the unlicensed individual. Subdivision 12(d) repeats that responsibility.
Tip
Phone calls, video calls, and photos do not satisfy direct supervision, no matter how experienced the apprentice is. "Physically present and immediately available" is the test.
Ratios and other limits in 326B.33, subdivision 12
| Rule | Requirement |
|---|---|
| Registration | An unlicensed individual must first register with DLI before doing work that requires a license |
| Supervision | Unlicensed work must be under the direct supervision of an individual licensed to perform that work |
| Same employer | The licensed and unlicensed individuals must be employed by the same employer |
| Ratio, general | A licensed individual may supervise no more than two unlicensed individuals |
| Ratio, technology | For technology circuits or systems work, the limit is three |
| No supervising by unlicensed | Unlicensed individuals may not supervise electrical work or make assignments to other unlicensed individuals |
| Planning and layout | Only a master electrician or power limited technician may plan or lay out electrical work, except for exempt technology circuits |
| Records | Contractors must keep records identifying all unlicensed individuals doing electrical work and let DLI copy them |
The two-to-one ratio applies to the type of work, not to the size of the job or the danger of the task. The Act has no separate one-to-one ratio for services or energized work. A licensed journeyworker may supervise up to two registered unlicensed individuals on any electrical work the journeyworker is licensed to perform.
DLI's summary for workers adds practical points. You may do electrical work as a registered unlicensed electrician only within the scope of work your employer is authorized to perform, only under direct supervision at all times by a licensed journeyworker or master, and only when you and your supervisor work for the same licensed contractor or registered employer. A licensed employee of one company cannot supervise the unlicensed employees of another company.
Who may do electrical work at all
DLI states that you may do electrical work in Minnesota only if you are at least 17 years old, licensed by DLI or registered as an unlicensed electrician, and a W-2 employee of a licensed electrical contractor or registered employer, or the owner of a licensed contractor. Minnesota Rules part 3800.3500, subpart 3 defines employee as an individual whose pay for electrical work is reported on a W-2, plus the instructor and students of an electrical wiring course working on school projects under a licensed contractor employee's direct supervision. A 1099 subcontractor is not an employee for this purpose.
Exemptions from licensing (326B.33, subdivision 21)
The Act lists situations where no personal license is required:
| Exemption | Conditions |
|---|---|
| Employer maintenance electricians | Maintain and repair the employer's own equipment on its property, under supervision of a licensed master, maintenance electrician, power limited technician, or electrical engineer, with a current certificate of responsible person on file |
| Technology circuits under a contractor | Employees of a licensed electrical or technology system contractor supervised by a master or PLT may install most Class 2 and Class 3 circuits, except listed items such as remote-control circuits controlling non-Class 2/3 circuits outside dwellings, Class 4 circuits, and work in hazardous locations |
| Plug-connected appliance controls | Class 2 and 3 remote-control wiring for plug or cord-and-plug connected appliances, other than security or fire alarm systems, in a residential dwelling |
| HVAC contractors | HVAC and refrigeration contractors and their employees doing HVAC work described in section 326B.38 |
| Utilities | Employees of electric, communications, railway, cable, or telephone utilities working on utility-owned facilities used for the utility function, not on the load side of the service point |
| Owners | An individual who personally performs electrical work on a residential dwelling they own and actually occupy, or will occupy on completion, if the dwelling has a separate electrical utility service not shared with any other dwelling |
| Elevator contractors | Companies licensed under 326B.164 doing elevator work |
The owner exemption is narrow. It covers only the owner personally, only a dwelling the owner occupies, and only a dwelling on its own utility service. It does not let an owner hire an unlicensed helper, wire a rental unit, or work on a duplex with a shared service. Even exempt owners must still file a request for inspection, because inspection under 326B.36 is a separate requirement.
Worked scenarios
Scenario 1 — Three apprentices. A journeyworker is assigned three registered unlicensed workers to rough in a strip mall. The ratio for general electrical work is two. One worker must be reassigned to another licensed electrician of the same contractor before work continues.
Scenario 2 — Supply-house run. A journeyworker leaves a registered apprentice terminating devices while picking up material across town for an hour. During that hour the journeyworker is not physically present and immediately available, so the apprentice's work is not under direct supervision. The apprentice must stop until a licensed electrician of the same employer is on site.
Scenario 3 — Borrowed apprentice. A licensed journeyworker from Contractor A offers to supervise an idle registered apprentice employed by Contractor B. This is not allowed because the licensed and unlicensed individuals must be employed by the same employer.
Scenario 4 — Low-voltage crew. A licensed power limited technician supervises three registered unlicensed workers pulling Class 2 data cabling. The technology-circuits ratio of three allows this crew size.
How many registered unlicensed individuals may one licensed journeyworker supervise on general (non-technology) electrical work under Minn. Stat. 326B.33, subdivision 12?
Two
One
Three
Four
Which arrangement meets the definition of direct supervision in Minn. Stat. 326B.31, subdivision 16?
A master electrician reviews photos sent by the apprentice and approves the work by phone
A journeyworker checks in at the start and end of each day and is reachable by phone in between
A journeyworker of the same employer is on site all day, immediately available, and reviews the work
A licensed journeyworker employed by a different contractor on the same site watches the apprentice all day
A homeowner wants to wire a finished basement in the single-family home they own and live in, which has its own utility service. What does Minn. Stat. 326B.33, subdivision 21 allow?
The owner needs a Class A journeyworker license before starting the work
The owner may personally do the work without a license, with inspection
The owner may hire any friend to do the work without a license
The owner may do the work only if a registered unlicensed individual assists on site
Sections you finish are checked off in the contents.