Published date: 09/17/2025
Aliecia Taormina, CCEP, MCA has over 20 years of experience in construction (including a role as a Senior Compliance Manager of a Fortune 300 contractor), accumulating extensive prevailing wage and Davis-Bacon knowledge over her career.
Question
Hi Aliecia, We have added a new scope of work and I am not sure how we identify the trade classification for prevailing wage compliance. I have contacted the Research OD team at the DIR, but was told it would be on a case by case basis and determined by the Awarding Body on the project.
We have over 100 active state and federal projects and logistically it is not feasible for us to open that can of worms – though I am afraid that the misclassification may come back to hurt us. Do you have insight on how we can explicitly determine a trade’s PW classification?
For further details, this concerns tub/shower installs (no connecting to plumbing, turnkey install includes screw into frame and caulking sealant) and the local affiliated with our other scopes of work have accepted the tub/ shower install into their union under the Fire Safety Technician class (we are non-unio, but they are the union we work with on PW projects). Our workers on PW jobs are classified as Fire Safety Technicians (which is very obviously not what they are doing). Please help!
Answer: Thank you for your question. I understand how the scope of work in this context can be unclear, and I appreciate the opportunity to provide clarification. To begin, I’d like to reference the California Department of Industrial Relations (DIR). According to their guidance, shower stall installation is classified under the Plumber trade. You can find this classification detailed in the following link, here.
However, I understand what may be your hesitation since you don’t connect to plumbing (as stated).
Regarding federal classifications, the U.S. Department of Labor (USDOL) typically determines the appropriate category by evaluating either:
- The area of practice in which the work is performed, or
- The union’s scope of work, which outlines the tasks associated with each classification.
This approach helps ensure consistency across jurisdictions while respecting local and union standards. In my humble, personal opinion, I believe you’re doing as much as you can. Make sure that you document all your conversations and store them with any written communication so that you can reference all of it in the event an agency takes exception to your choice.
Question
I have a job in Northern NV Rural that requires zone pay for Laborer Grp 3. My question is, do I pay the 6.00 zone 2 pay per hour worked, or only for travel time to the job site?
Answer: Great question! After looking into the 2024–2025 prevailing wage determination for the Northern Nevada Rural Region, it appears that zone pay for laborers, including Group 3, is calculated per hour worked, not just for travel time. Specifically, for Zone 2 (75 to 150 miles from either the Carson City Courthouse or the Washoe County Courthouse), an additional $6.00 per hour is added to the base wage rate for all hours worked on the project.
Please note that zone pay does not apply within ten (10) miles of the employee’s permanent residence in Nevada. As always, don’t hesitate to confirm with the Nevada Labor Commissioner office. They really are friendly and want nothing more than to help all contractors!
Question
When entering hours do we enter the number of hours actually worked or do we enter the hours according to union rules? For example, one union has a 4-6-8 rule where if the employee works more that 4 hours but less than 6 hours, we pay 6 hours. When completing the CPR entries, would we enter the hours actually worked or the hours we paid?
Answer: Oooh, this is a really good question. I have had to research this myself in the past when this has come up. When completing Certified Payroll Reports (CPRs), the hours entered should reflect the actual hours worked by the employee on the project site. The system is designed to capture factual labor data, and entering actual hours ensures compliance with federal reporting standards, particularly those outlined in the WH-347 form. While union agreements—such as the 4-6-8 rule—may require payment for more hours than were physically worked, this distinction should be handled within your payroll system. The CPR should still report the actual hours worked, not the hours paid, unless your agency or project administrator has specifically instructed otherwise.
If your project has unique reporting requirements or if you’re unsure how your union rules intersect with CPR entries, it is recommended to confirm with your project’s labor compliance officer or administrator.
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