Ep007 - The Underground Economy Revisited

Soussanna Karas: We consider licence holders, professionals. We consider them as our safety partners and they have a very responsible role to play in our community. They're advising consumers, they are invited in their houses, in their homes, in their businesses. Consumers trust the contractors for their advice and trust to have their best interest in heart, which is why we at ESA take it very seriously when licence holders do not comply with those responsibilities or act without honesty and integrity.

Karen Ras: Last year, the Electrical Safety Authority issued more than 1300 notices of violation, launched more than 100 investigations and convicted 48 unlicensed electrical contractors across Ontario. In this episode, we'll get an update on ESA's enforcement efforts to protect consumers and learn more about proposed improvements that will make it even easier for you to do business. 

Grounded in Ontario is a podcast for you, the province's licensed electrical contractors, master and certified electricians and offers safety tips, tech, and best practices. Now let's get grounded.

Hello and welcome to another episode of Grounded in Ontario. I'm Karen Ras and I work for ESA as Director of Communications, Stakeholder and Government Relations. I'll be taking over as the new host for Grounded in Ontario, as Josie Erzetic takes over the helm as CEO for ESA. This podcast was a real passion of hers. It was her idea to create this platform as a way to connect with all of our stakeholders. And it worked! Grounded in Ontario is now in the top 10% for all podcasts globally. And I'm excited to pick up the baton. 

Today, we're talking all about licensing. Everything from enforcement blitzes to digital enhancements, we're currently in the process of implementing. Over the past year, the licensing team supported by our colleagues across ESA have worked hard to deliver services to licence holders, monitor compliance, take steps to curtail the underground economy and most importantly, engage with all of you, our stakeholder community.

With me today is Soussanna Karas, Director of Licensing. And she's going to talk to us a little bit about what she and her team are doing to make it easier for all of you to do business. Soussanna, how are you doing today?

Soussanna Karas: I'm doing great, Karen. Thank you for having me on this episode. I'm excited about talking about the underground economy.

Karen Ras: I know your team is very passionate when it comes to protecting consumers and providing value to our licence holders. Last time you were on this podcast, we spoke about some of your enforcement blitzes to target the underground economy. In particular, we spoke about a trend you were seeing with respect to the illegal installation of pot lights. I'm wondering if you can give us an update on this.

Soussanna Karas: Illegal installations of pot lights continues to remain an issue that we are seeing. We keep receiving reports from our stakeholders directing us to illegal installation of pot lights. And that includes both pot lights being installed by unlicensed contractors who have been retained to do that, and failure to file notifications. A little bit about numbers. We've received over 600 reports of installations performed by illegal contractors without notifications. We have conducted a blitz, mostly focusing on the Brampton area because that's where most of the reports directed us to. The objective of it was, number one, educate. Number two, to ensure that the homeowners understand their obligations with respect to notifications and know that their installation is safe. And number three was to respond to those reports that we received. In terms of numbers, I can share with you that we issued 359 letters to licensed electrical contractors, and we reminded them of the obligation to file notification.

And we also reminded them about their obligation to subcontract only those who are licensed or to have electrical workers on their payroll. We also did communication outreach on Facebook. And this time we did it in three languages, English, Urdu and Punjabi. We visited homes. Our inspectors visited 427 Brampton locations and left over 400 door hangers in three different languages, educating homeowners about their obligations and letting them know that their electrical safety is our number one concern.

We also visited six electrical suppliers, those who sell pot lights, educating them about Electrical Safety Authority about hiring LEC and about filing notifications. Overall, this has been a successful campaign, but we do continue to receive reports from members of the public. In other words, this continues to be a problem in the province. What I would like to do is to tell our listeners, when you hear or see illegal installation of pot lights, please do report it to us. There is an online button on our website where you can file your report. But please do you include as much information as possible about what you're seeing, the address, the name, that will help us immensely in trying to figure out who did what and trying to structure compliance and enforcement activities accordingly.

Karen Ras: I really love that your team took the time to translate materials into different languages. It was a true grassroots effort, and that really helps homeowners understand why they should hire a licensed electrical contractor for these types of jobs and the importance of filing notification with the ESA, particularly if English isn't their first language. And with respect to that, what's been your experience with this Soussanna.

Soussanna Karas: We all live in this great multicultural and multilingual community called Ontario, and we care greatly about access to information that our stakeholders should have with respect to safety, specifically electrical safety. As you've heard before, we do try to draft our messages in a different way, in different languages to provide this access. And in terms of the access and education generally, raising awareness and education is ESA's first priority. It's our mandate. What we believe is the power of education changes behavior. Right? We have what we call a compliance pyramid, which is applicable to our licence holders. And I spoke about this at the last podcast. What it is is, it's an approach that we take where the first and foremost foundational activity that we take when we find non-compliance is to educate. We then direct. And only if we see a pattern of non-compliance, if we see that somebody understands their rights and obligations, but refuses to comply with them, only then we go investigate and prosecute. It has worked great because we do believe that the majority of stakeholders that we work with, they care about safety and they want to change their behavior.

Karen Ras: It seems to me like it's adding a speed camera to our roadways. You typically see an increase in compliance after these types of blitzes. Changing lanes a little bit, I know EV charging systems are an area that we really zoned in on as well for compliance and we have seen success. I'm wondering if you can give our listeners an update on our EV blitz.

Soussanna Karas: So what I'm happy to report is that in the period of 2021, compared to the same period of 2020, an increase of 87% in notifications filed. In my opinion, it's a great result. It shows that people now understand their obligations, and they do want to ensure that EV charges are installed safely. And given the increase in gas prices and interest in purchasing EV vehicles, the EV charges will continue to be on our radar, will continue to look into the notification, continue to track it and will perhaps revisit this issue again.

Karen Ras: Well, I'm glad to see that this program is expanding and we know that EVs are only growing in popularity, and it's important to get the word out and how to install charging equipment safely. I mean, homeowners need to protect those investments. This could mean partnerships at dealerships and organizations such as Plug'n Drive. Speaking of partnerships, are there any new partnerships you're exploring Soussanna?

Soussanna Karas: We always look at the partnerships with our safety partners. We always explore opportunities to educate, to promote and to change behavior. One of such partnerships is the partnership with WSIB, that we've done in two phases. Phase number one finished last year. And that was to look at all the businesses that are licensed with or insured with WSIB under the category of electrical contractors. We took that information and looked at our records to see if the businesses that are insured with WSIB have corresponding licences with ESA. Those who did not, we contacted for information and explanation.

Phase number two was to follow up on those who did not respond to phase number one. We followed up on those who requested to be an LEC and did not become licensed, or who failed to respond to us or admitted to being a subcontractor. Those were the three categories that we picked. Through letters and phone calls, I'm happy to say that 80% of those who we contacted in phase two have come into compliance. The remainder, we've monitored, and we will continue to monitor to see if the continuous compliance is achieved.

Karen Ras: Well, that's good to know. It sounds like a good initiative. What about previous licence holders who no longer have an active account? How does ESA follow up with that?

Soussanna Karas: When we talk about the underground economy, truly those who operate without a licence truly are in the underground economy. The biggest concern that we have is with respect to those who have been licensed with ESA, which means that they understand and they know their obligations, they actually have been licensed, and now they're no longer holding the licence with ESA, they're continuing to operate. So that's the focus of this pilot, where we looked at social media, advertisements, website, testimonials of the recent activity of those, both master electricians and licensed electrical contractors who lost their licence in the last few years.

So they either have been suspended, revoked, or expired. And if we see evidence that they're actively engaged in a business of an electrical contractor, we will send those cases to investigations. We will not... and this is the example of compliance permit that I talked about earlier, where in this case we do see systemic non-compliance, where this is somebody who knows their obligations and decided not to comply with them. In my mind, this is my biggest concern because behavior such as this disrupts the level playing field, it undermines consumer confidence in the industry and really, it brings disrepute to the profession.

Karen Ras: You bring up a good point, Soussanna. Licence holders are expected to conduct themselves with honesty and integrity. And we know the vast majority of them do. They are expected to follow the laws established to protect Ontarians. I'm just curious, are you receiving an increase in consumer complaints about this?

Soussanna Karas: That vast majority of licence holders share ESA's commitment to safety and compliance. In fact, I don't think you will find a more committed and passionate group about electrical safety and the group that actually does exemplify those rules in their day to day life and their day to day business. However, there are some that are not, and we do receive complaints from the members of the public, and we do take those seriously. What we usually do is, we allow an opportunity for the LEC to provide their side of the story. We try to work with both parties to understand what happened and to see if there has been, in fact, a breach of the regulation.

We do believe, and we truly practice day to day, that LECs have an obligation. They have to exemplify the behavior, the safe behavior with the community. And we want to make sure that these messages are not just empty messages and the consumers also see that.

So one of the examples that we've seen unfortunately, is, and one of trends where DME, the Designated Master Electrician is not compliant with their obligations. We do believe, and the legislation supports it, that the role of the Designated Master Electrician is an important one in the business. They are supposed to personally oversee the activities of the LEC. They are supposed to ensure that the LEC business complies with the Code and with all other legislation. When a DME is appointed and they fail to fulfill those obligations, we take those cases very seriously. And we do investigate and we look into it and we come up with the compliance actions where required. The trust in the electrical contracting trade in the industry is established by LECs acting with honesty and integrity. And we want to work with our community to ensure that that happens every day with no exception.

Karen Ras: And on some of those points, maybe you can expand upon some of those examples of what might constitute, not protecting consumers or failing to act with honesty, integrity, just so we're all clear.

Soussanna Karas: Yeah. So by no means this list that I'm going to share is inclusive. There's some examples that we've seen in the past. And those examples might include charging a consumer for services not provided or misrepresenting the need for repair. Consumers rely on licence holders as professionals. So this is very important to carry out their activities with honesty and integrity. Not filing notifications or filing notifications that do not include the full scope of work. Charging consumers for permit fees when the permit or notification has not been taken out, or it's not required. Invoicing for original and new parts while installing inferior or different parts. We're talking about electrical parts. And taking advantage of a consumer in an emergency situation where the price that is being charged greatly exceeds the price that would've been charged in a regular situation.

Karen Ras: I think you raised a good point, Soussanna. Occasionally we hear about these stories during severe weather storms, especially relevant given the massive windstorm that took place in May. And we hate to hear stories of unlicensed electrical contractors who are looking to take advantage of vulnerable homeowners in a desperate situation. And that's why ESA, we're always prepared to promote the need to hire an ECRA/ESA licence holder so that homeowners don't fall into this trap. But it's an important reminder even for our licence holders, that we must hold ourselves to a higher standard so we can maintain public trust.

Soussanna Karas: As I mentioned, we consider licence holders professionals, we consider them as our safety partners and they have a very responsible role to play in our community. They're advising consumers, they're invited in their houses, in their homes, in their businesses, consumers trust the contractors for their advice and trust to have their best interest in heart, which is why, we at ESA, take it very seriously when licence holders do not comply with those responsibilities or act without honesty and integrity. So I encourage our licence holders to look up standards of conduct and guidelines. Those are very important resources.

Karen Ras: And for our listeners, we also regularly post licensing updates in PluggedIn, our quarterly newsletter. It's certainly an excellent resource and you'll get updated on convictions, licensing and technical matters. Just to name a few. And I look forward to reading through it whenever it comes out. And Soussanna, I'm just wondering, do all licence holders receive a copy of PluggedIn automatically?

Soussanna Karas: Yes. So that is correct. All licence holders of whom we have email addresses will receive PluggedIn automatically. If we do not have your email address on file, we will not be able to send it to you because we are digitizing our services and PluggedIn goes via email. So on that note, I would greatly encourage our licence holders, all of our listeners to either go on a website and download the form or call our licensing hotline to inquire how you can provide your email as a contact information for us. We want to have your valid email address on file, because this way you can access our self-serve portals, and you can do business much faster, much more effective and efficient with ESA.

Karen Ras: And certainly, we have a goal to become a more modern regulator. And as part of that plan, we need to provide digital enhancements. And I'm just wondering, Soussanna, if you can elaborate on some of ESA's self-serve portals, that will make it easier for our license holders to navigate our processes.

Soussanna Karas: Certainly COVID was a great indicator of how businesses can be disrupted unless they are conducted in a digital way. So we took a lot of steps to ensure that we have self-serve portals available to our licence holders. So we have a master electrician portal where they can renew their licence. Once they create an account, they can log in, see their invoices and make a payment online. This eliminates the need to call in, to send a check, eliminates the delays and the frustration. So it can be done in real time. We also have an LEC portal where they can track notifications, see account updates, make account payments, and they can also renew their license. And finally, which we are really excited, we're currently working with our partners in IT to create a full online renewal portal, which will combine the two that I mentioned before. It will be open to both LECs and MEs. It will have much more capacity for you to do business with us, upload documents, submit your forms, receive your license, and make a payment, which we hope to come on soon, but we're working on it currently.

Karen Ras: Thank you, Soussanna. Now I'm going to shift gears a bit and have you answer a question that was sent to us by one of our listeners. We love when our audience sends questions and topic ideas, so please keep them coming. And it could be featured in an upcoming episode. You can email us at This question has to do with homeowners and why they are allowed to pull their own electrical permits. Does ESA have any plans to do anything about this?

Soussanna Karas: So in answering this question, I have to say this, ESA is an administrative authority. We do not write the laws. We enforce the laws as they've written. And in that respect, there's two pieces of legislation that we are governed by. And that's the Electricity Act, and the licensing regulation. Both those pieces of legislation contain a provision that allows homeowners to conduct electrical installation in their own home. So they do have that right and they don't have to hire a licensed contractor. They can do it on their own, provided it's in their own residence and provided they file a notification with ESA.

So having said that, we always encourage, and I spoke of this earlier today, we encourage homeowners to hire LECs. We have a number of LEC campaigns that we conduct. And in those, we educate homeowners about risks of doing electrical installation on their own, the complexity of the work and the benefits of hiring licensed electrical contractors. So we do have this work ongoing in this campaign. We always recommend hiring LECs and we always say that LECs have the expertise, the equipment, and the training to do electrical work safely, which is why it's in the best interest of the consumers.

Karen Ras: Excellent. Now, would you happen to have that date available for the next licence holder meeting?

Soussanna Karas: Yes, absolutely. November 23rd is the date for our next license holder meeting. It will be conducted virtually again, as it has been in the last two years. We found that this is a very good mode for the meeting. It allows our stakeholders from all over the province to connect and they don't have to drive. We found that this is a very good way to interact and engage. So please put this date in your calendar. November 23rd. There will be more communication in PluggedIn. Please check out Plugged In regularly for the times and ways to register.

Karen Ras: Thanks, Soussanna. That was great information, and it was really appreciated that you're updating all of our listeners on the fantastic work that you and your team are doing to help make these processes easier for our license holders, but also at the end of the day, make Ontario a safer place.

Soussanna Karas: Thank you.

Karen Ras: Thanks for listening to Grounded in Ontario. If you have any questions on this topic or any other electrical safety topic, we want to hear from you. Email us at We plan to answer some frequently asked questions in future episodes. Make sure you follow this podcast wherever you get your audio content, so that you'll get notified about new episodes. Until next time, be safe, work safe, and stay grounded.