Published date: 03/19/2026

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

We are a small, non‑union utility locating company with one full‑time employee (the owner) and one part‑time employee. We do not meet the 1:5 journeyman‑to‑apprentice ratio and rarely work more than 40 total hours on a project. Are we still required to submit a DAS 142, and how do the ratio and total hours worked affect that requirement?

Answer: I do so love the confusing California work, but I do need to tell you that under California Labor Code §1777.5, contractors are required to submit a DAS 142 when the applicable apprentice‑to‑journeyman ratio is not met, regardless of contractor size, total project hours, union status, or apprentice availability. The DAS 142 documents a good‑faith request for apprentices and is required even if no apprentice is ultimately dispatched or the project involves limited hours.

Question

How do you determine wage rates for federal projects that are dual projects with Canadian companies?

Answer: Great question! For federal construction projects located in the United States, Davis-Bacon Act (and Davis-Bacon Related Acts) prevailing wage laws apply based on where the work is physically performed, not the nationality of the contractor or ownership structure. If the work is performed on the U.S. side of the border, workers must be paid Davis‑Bacon prevailing wages for the applicable locality and construction type even if the contractor is Canadian. If work is performed in Canada, U.S. prevailing wage laws generally do not apply unless a specific federal statute, treaty, or contract clause explicitly extends U.S. labor standards extraterritorially.

We are performing a Geotechnical Engineering Exploration for a solar project. The individuals who are operating drill rigs and pile installation equipment will be paid prevailing wage, and we will have an apprentice with them. Another study we are performing is a geophysical study which is performed by college educated, trained geophysicist. The study has a field-testing portion which requires hammer in metal stakes to the ground so ready electrical signals. But then the collected field data is brought back to the office where they evaluate the data and generate a report. Should this group be paid prevailing wage or have an apprentice? If so, what specifically determines that?

Answer: This is a very good question, and the answer depends on the actual duties performed rather than job titles. For the geotechnical engineering exploration, individuals operating drill rigs and performing pile installation are generally considered laborers or mechanics because they are performing on‑site, physical work that is integral to construction; therefore, prevailing wage applies, and apprentices may be used only if they are properly registered and paid the applicable apprentice rates. In contrast, the geophysical study is typically considered a professional service: although it includes limited field work such as hammering stakes to collect data, that activity is incidental to the primary purpose of scientific analysis and report preparation performed in the office. Provided the field work is limited, not in direct support of construction crews, and does not involve sustained manual labor, the geophysicists would generally not be subject to prevailing wage or apprenticeship requirements.

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