During the current drought, many new water wells have been drilled in California and many existing wells have been re-drilled to access deeper groundwater. The WCIRB has received calls regarding classifications applicable to water well drilling and related operations.
The California Workers’ Compensation Uniform Statistical Reporting Plan—1995, (USRP), contains an N.O.C. or not otherwise classified drilling classification applicable to water well drilling:
|DRILLING – N.O.C. – not geothermal, oil or gas producing, mining or quarrying
At a particular job or location, this classification shall not be used for division of payroll in connection with any other classification (other than the Standard Exceptions or General Exclusions).
Classification 6204 is listed in Appendix I of the USRP as a Construction and Erection classification, and is therefore subject to the USRP provisions at Part 3, Standard Classification System, Section IV, Special Industry Classification Procedures, Rule 2, Construction or Erection Work.
It is important to note that Classification 6204 contains a restriction regarding division of payroll in connection with any other classification (other than the Standard Exceptions or General Exclusions) at a particular job or location. The restriction is significant as additional construction or erection operations are often performed at a water well drill site, such as the installation of water pumping equipment. Based on this restriction contained in Classification 6204, when the same employer drills a water well and performs additional operations, such as the installation of a pump at the same job or location, all work at the job or location must be classified as 6204, Drilling.
When the installation or repair of water pumping equipment is performed at a job or location where no drilling is performed by the employer (such as to repair or replace pumping equipment at an existing well), Classification 3724(1), Millwright Work, is assigned to such operations.
It is common for employers that specialize in water well and water pump work to divide payroll between Classification 6204 at drill sites and 3724(1) at sites that do not include drilling operations, subject to the payroll division requirements contained in Rule 2, Construction or Erection Work.