Plumbing subcontractors
Plumbing subcontractor COI requirements
Plumbing losses are water losses: a failed fitting above a finished floor, a test plug that lets go over the weekend, a slow leak that becomes a mold claim. Plumbing COIs fail when the policy behind them excludes exactly those outcomes through fungi, continuous damage or pollution wording, or when completed operations status lapses before the first tenant moves in.
Plumbing audit
Clearwater Plumbing & Piping Inc.
Cedar Ridge Senior Living
- CGL policy
- GL 4402-7719-06
- AM Best
- A- VII
- Carrier
- Tidewater General Insurance Co.
- DeficientCG 21 67
Fungi or bacteria exclusion; no CPL policy covering mold.
- ReviewCG 20 37
Completed operations AI edition 07 04 does not match CG 20 10 04 13.
- DeficientManuscript
Continuous or progressive damage exclusion on the CGL.
- of plumbing subcontractor COI packets are deficient on first review
- 65%
- of plumbing subcontractor COI packets are deficient on first review
- Pikorua Security 2026 Benchmark
- trade rank by defect rate, 6 points below the all-trade average
- 10 of 14
- trade rank by defect rate, 6 points below the all-trade average
- Pikorua Security 2026 Benchmark
- of subcontractor and vendor COIs contain material coverage deficiencies or missing endorsements on first review
- 71%
- of subcontractor and vendor COIs contain material coverage deficiencies or missing endorsements on first review
- AGC Risk Committee Audit
- of COIs claiming additional insured status fail to attach the CG 20 37 completed operations endorsement
- 64%
- of COIs claiming additional insured status fail to attach the CG 20 37 completed operations endorsement
- IRMI Construction Risk Survey
Typical exhibit
Typical plumbing insurance requirements
- Rules in template
- 14
- Hazard tier
- Significant
| Coverage | Typical limit | What to check |
|---|---|---|
| Commercial general liability (CG 00 01, occurrence) | $1,000,000 each occurrence / $2,000,000 general aggregate | Per-project aggregate via CG 25 03. Water losses on occupied renovations can consume a shared aggregate fast. |
| Products-completed operations aggregate | $2,000,000 | Most plumbing claims are post-completion water damage. This is where the money is paid. |
| Business auto liability | $1,000,000 combined single limit | Service vans and trucks carrying pipe and fixtures; hired and non-owned included. |
| Umbrella / excess liability | $5,000,000 each occurrence and aggregate | Raise on high-rise residential, hospitals and labs, where one riser failure can flood many floors. |
| Workers compensation / employer's liability | Statutory / $1,000,000 each accident, $1,000,000 disease each employee, $1,000,000 disease policy limit | Trench and confined space work on site utilities raises the severity of plumber injuries. |
| Contractors pollution liability | $1,000,000 each condition / $2,000,000 aggregate | Sewage backups, mold from leaks and Legionella in domestic water systems are pollution claims under many CGL forms. |
Endorsement checklist
Forms to see attached, not just checked
- CG 20 10Additional insured, ongoing operations
- CG 20 37Additional insured, completed operations
- CG 20 01Primary and noncontributory
- CG 24 04Waiver of subrogation on general liability
- WC 00 03 13Waiver of subrogation on workers compensation
- CA 20 48Designated insured for covered autos liability
- CG 25 03General aggregate applies per project
Exclusion watchlist
Exclusions that void plumbing coverage
- Red flag
CG 21 67 Fungi or Bacteria Exclusion
A slow leak inside a wall becomes a mold claim within weeks. With CG 21 67 attached, the CGL excludes the mold component, which is often the most expensive part of a water loss.
- Red flag
Continuous or progressive damage exclusion
Carrier manuscript wording that excludes damage that began before the policy period or continued across policy periods. Slow plumbing leaks are the textbook example, and this exclusion lets a carrier deny claims that span renewals.
- Red flag
Water damage or water intrusion exclusion
Some carriers exclude water damage outright for residential or mixed-use projects. For a plumbing sub, that removes the core exposure.
- Red flag
CG 21 44 Limitation of Coverage to Designated Premises, Project or Operation
Small plumbing contractors sometimes carry a policy limited to scheduled operations, such as service and repair only. New construction rough-in and trim on your project may sit outside that schedule.
Read the CG 21 44 guide
Why water losses decide plumbing compliance
A plumbing subcontractor's insurance is tested almost entirely after the work is done. The pipe is tested, the walls close, and the failure comes later as a burst fitting, a cracked cleanout or a pinhole leak that runs for months. That makes three things decisive: completed operations additional insured status (CG 20 37), a products-completed operations aggregate that has not already been eroded, and the absence of exclusions that carve water and mold out of the policy.
Pikorua Security's plumbing template looks past the limits on the ACORD 25 to the schedule of forms on the declarations page, where CG 21 67 and continuous damage wording appear. A plumbing packet with both, and no pollution policy, is flagged deficient even when every limit clears the exhibit.
Sewage, mold and Legionella are pollution claims
Under many CGL forms, sewage is a pollutant. A backup during a tie-in or a cross-connection in a domestic water system can trigger the pollution exclusion even though nobody thinks of a plumber as an environmental contractor. Legionella in hot water systems and mold from leaks follow the same path.
Require contractors pollution liability on any plumbing scope that includes site utilities, sewer tie-ins, domestic water in healthcare or senior living, or renovation inside an occupied building. Ask for the GC and owner to be named as additional insureds on the CPL policy, not just the CGL.
- Occurrence-based CPL is preferable; if claims-made, check the retroactive date.
- Confirm the CPL covers mold and Legionella explicitly.
- Match the CPL completed operations period to your subcontract.
Testing, turnover and renovation work
On renovation projects in occupied buildings, plumbing work happens above tenants and their property. A test failure on a Friday can damage several floors before anyone notices. Make sure the sub's CGL does not limit property damage on existing structures, and require the umbrella to follow form over the CGL without a water damage restriction. Pikorua Security flags renovation projects automatically when the project type is set to occupied renovation, and adds those checks to the plumbing template.
How to verify a plumbing sub's COI
A manual review of one COI and its endorsement packet takes 25 to 40 min (CFMA Time Study). These are the six checks, in the order Pikorua Security runs them.
- 1
Match the named insured to the subcontract
Compare the named insured on the ACORD 25 with the legal entity that signed the plumbing subcontract, including the LLC or Inc. suffix. A trade name or DBA is not the contracting entity, and additional insured coverage follows the policy's named insured.
- 2
Check limits against your plumbing exhibit
Confirm commercial general liability of $1,000,000 each occurrence / $2,000,000 general aggregate, an umbrella of $5,000,000 that follows form over CGL, auto and employer's liability, and statutory workers compensation. Then confirm contractors pollution liability is evidenced, because it does not appear on a standard ACORD 25.
- 3
Read the endorsement pages, not the checkboxes
A Y in the ADDL INSD or SUBR WVD column is not an endorsement. Confirm CG 20 10, CG 20 37, CG 20 01, CG 24 04, WC 00 03 13, CA 20 48 and CG 25 03 are attached as forms, and that the ongoing and completed operations forms share the same edition date.
- 4
Scan the schedule of forms for plumbing exclusions
Look for CG 21 67 Fungi or Bacteria Exclusion, continuous or progressive damage exclusion, water damage or water intrusion exclusion and CG 21 44 Limitation of Coverage to Designated Premises, Project or Operation. None of these appear on the certificate; they sit in the declarations schedule of forms and the endorsement pages.
- 5
Check carrier ratings and policy dates
Confirm each carrier is rated A- VII or better by AM Best and that no policy expires before the plumbing scope and its completed operations period are finished. Set renewal reminders at 60, 30, 15 and 0 days.
- 6
Hold payment and site access until resolved
Keep the plumbing sub's pay applications and jobsite badges on hold until every finding is resolved, then file the verified packet so it is ready if you ever need to tender a claim.
Try it
Is this plumbing COI compliant?
What the packet from Clearwater Plumbing & Piping Inc. shows
04 13 or later edition
OKEdition matches CG 20 10
OKWith no mold coverage elsewhere. Red flag if present.
GapCovers sewage, mold, Legionella
GapCarrier manuscript wording. Red flag if present.
OKApplies to the GC and owner
OK
Switch on = present in the packet. Switch off = missing.
Deficient: 2 findings
CG 21 67 fungi or bacteria exclusion
Mold from a leak is excluded.
Contractors pollution liability evidenced
Sewage and mold claims have no policy.
Pikorua Security would send a deficiency notice to the sub and its broker citing each item, and hold payment until a corrected endorsement arrives.
Questions
Plumbing COI questions
What insurance should a plumbing subcontractor carry?
Is mold covered under a plumber's general liability policy?
Why do GCs need CG 20 37 from plumbing subs?
14-day free production trial
Check every plumbing sub's endorsements before they mobilize.
Upload your current plumbing certificates. Pikorua Security reads the endorsement pages, applies the plumbing template and shows every hidden gap in 10 minutes.