California CSLB Glazing Contractor C-17 Attorney Fee Petition Mechanics: Tyler Odyssey Civil Complaint Date as Primary Welch Anchor, CSLB License Check (C-17 Glazing Specialty) as Secondary Anchor (THE ONLY C-17 Glazing Contractor Specialty Page in This Series — ONLY Page With California Building Code § 2406 Safety Glazing Advisory in Hazardous Locations [Shower Enclosures, Doors, Stairways]; ONLY Page With California Energy Code Title 24 Part 6 Fenestration U-Factor/SHGC Advisory and NFRC Label Verification; ONLY Page With Glass Breakage Injury / Energy Code Non-Compliance / Weather Envelope Breach Three-Track Harm; Bus. & Prof. Code § 7031(b) Disgorgement), CLRA § 1780 Mandatory Attorney Fees

Statutory Framework: Bus. & Prof. Code § 7028, C-17 Glazing Specialty, CBC § 2406 Safety Glazing, Title 24 Part 6 Fenestration Requirements, § 7031(b) Disgorgement, and CLRA § 1780 Mandatory Attorney Fees

California Business and Professions Code § 7028 prohibits unlicensed contracting. The CSLB C-17 Glazing Contractor classification authorizes the installation of glass and glazing systems in buildings. Any person who performs C-17 glazing installation as a standalone trade for a contract price exceeding $500 in California without a valid C-17 license (or a B general building contractor license where glazing is merely incidental to a larger general project) violates § 7028.

California Building Code Section 2406 (Title 24 Part 2) establishes mandatory safety glazing requirements. Safety glazing materials — tempered glass, laminated glass (heat-strengthened with PVB interlayer), wire glass, and plastic glazing meeting CPSC 16 CFR Part 1201 — are required in designated hazardous locations where glass breakage presents a risk of injury. The primary hazardous locations for residential C-17 glazing work: (a) shower and bathtub enclosures (Section 2406.4.4) — all glazing in shower or bathtub enclosures must be safety glazing; (b) glazed doors (Section 2406.4.1) — all glazing in swinging, sliding, and bifold doors must be safety glazing; (c) glazing adjacent to doors (Section 2406.4.1) — glazing within 24 inches of a door and within 60 inches of the floor on either side of the door requires safety glazing; (d) glazing adjacent to stairways and ramps (Section 2406.4.3); (e) glazing in guards, handrails, and balusters (Section 2406.4.6). Annealed glass (standard float glass) shatters into large, sharp shards capable of causing severe lacerations, puncture wounds, and lacerations to major blood vessels — safety glazing (tempered glass) breaks into small, relatively harmless fragments; laminated glass holds in place after breakage.

California Energy Code Title 24 Part 6 establishes fenestration performance requirements for residential replacement windows and new glazing installations. The National Fenestration Rating Council (NFRC) certification label on each window unit is the primary compliance documentation, showing the NFRC-certified U-factor and Solar Heat Gain Coefficient (SHGC). CEC climate zone prescriptive compliance thresholds for fenestration vary by zone — an unlicensed C-17 contractor who installs replacement windows without confirming and documenting NFRC-certified compliance with the applicable climate zone requirements creates an energy code non-compliance.

Three Unique Distinctions in the Fee-Petition-Mechanics Series

• THE ONLY page with CALIFORNIA BUILDING CODE § 2406 SAFETY GLAZING ADVISORY — unlicensed C-17 glazing contractors who install annealed glass in hazardous locations (shower enclosures, glazed doors, door-adjacent glazing, stairway glazing) create non-code-compliant installations with life-safety risk; the CPSC safety glazing marking is the field indicator of code compliance or non-compliance: the CBC § 2406 safety glazing advisory generates pre-complaint hours unique to C-17 glazing matters: (a) the attorney must identify all glazing installed by the unlicensed C-17 contractor and confirm which installations are in CBC § 2406 hazardous locations — this requires a physical inspection or a detailed description from the homeowner of each glazed location; (b) confirming whether the installed glazing bears the required permanent safety glazing marking — safety glazing (tempered glass) manufactured to CPSC 16 CFR Part 1201 standards bears a permanent etched or sandblasted label identifying the safety glazing standard (e.g., "CPSC 16 CFR 1201 CAT. II" for tempered glass meeting Category II impact requirements); annealed glass typically bears no safety glazing marking; (c) if non-safety glazing is confirmed in a hazardous location, the remediation is complete glass replacement with safety glazing — the annealed glass cannot be treated or strengthened in place; the replacement cost for each non-compliant glazing unit (shower enclosure panels, door glass panels, sidelights) is recoverable as CLRA actual damages; (d) advising on the building permit requirement — shower enclosure glazing, door replacement, and window installations typically require building permits in California; an unlicensed C-17 contractor who installs glazing without a building permit creates an unpermitted installation requiring retroactive permit and inspection, adding advisory hours for permit regularization; (e) advising on the premises liability risk — a homeowner who continues to use non-code-compliant annealed glass shower enclosures or door glazing faces premises liability for injuries to guests from glass breakage; the attorney must advise on immediate replacement to eliminate the ongoing liability exposure; the CBC § 2406 safety glazing advisory generates pre-complaint advisory hours unique to C-17 glazing matters and found on no other CSLB specialty page in the fee-petition-mechanics series.
• THE ONLY page with CALIFORNIA ENERGY CODE TITLE 24 PART 6 FENESTRATION ADVISORY — the CEC requires minimum U-factor and SHGC values for replacement windows by climate zone; NFRC label verification confirms compliance; an unlicensed C-17 contractor who installs non-NFRC-certified or non-compliant windows creates an energy code non-compliance requiring HERS advisory and TDS disclosure: the CEC fenestration advisory generates pre-complaint hours unique to C-17 glazing matters: (a) identifying the applicable CEC climate zone and the prescriptive fenestration performance thresholds for that zone — CEC Residential Compliance Manual Table provides U-factor and SHGC limits by climate zone for both metal-frame and non-metal-frame windows; (b) confirming whether the installed replacement windows have NFRC-certified labels documenting U-factor and SHGC performance — windows manufactured by NFRC-certified manufacturers bear a label on each unit showing U-factor, SHGC, visible transmittance (VT), and air leakage; if no NFRC label is present, compliance cannot be confirmed without independent testing; (c) advising on whether a HERS Rater verification is required for the project type — certain residential window replacement projects require a HERS Rater field verification confirming that the installed windows match the NFRC-certified specifications submitted on the building permit; (d) quantifying the replacement window cost — removing and replacing non-NFRC-certified or non-compliant windows with code-compliant products — as CLRA actual damages; for a full house window replacement project, this may range from $5,000 to $30,000+; (e) advising on TDS disclosure obligation — energy code non-compliant windows are a known defect requiring disclosure under Civil Code § 1102.6 in future sale; the CEC fenestration advisory generates pre-complaint advisory hours unique to C-17 glazing matters — the second California Energy Code advisory in the fee-petition-mechanics series (alongside C-2 Insulation's CEC R-value advisory) but this page is THE ONLY page applying the CEC fenestration advisory to replacement window U-factor and SHGC compliance.
• THE ONLY page with GLASS BREAKAGE INJURY / ENERGY CODE NON-COMPLIANCE / WEATHER ENVELOPE BREACH three-track harm — three independent harm tracks from unlicensed C-17 glazing installation, each generating distinct CLRA actual damages and unique advisory hours: the three harm tracks are: Track 1 — GLASS BREAKAGE INJURY: non-safety glass (annealed glass) installed in CBC § 2406 hazardous locations — shower enclosures, glazed doors, door-adjacent sidelights — presents an ongoing personal injury risk; when annealed glass breaks from impact, thermal stress, or accidental contact, it shatters into large, sharp shards that have caused severe lacerations, puncture wounds to major arteries, and fatalities; Track 1 generates CLRA actual damages for immediate safety glazing replacement at all hazardous locations plus advisory hours for the premises liability exposure during the period of non-compliant glazing use; Track 2 — ENERGY CODE NON-COMPLIANCE: windows that fail to meet CEC climate zone U-factor and SHGC requirements result in higher heating and cooling loads — measurable as increased HVAC energy consumption; an energy audit quantifying the annual energy overcost from non-compliant windows can generate an ongoing damages theory beyond the one-time replacement cost; the CEC non-compliance also creates TDS disclosure obligation for future sale; Track 3 — WEATHER ENVELOPE BREACH: improperly installed window frames — missing or inadequate waterproofing membrane at the window rough opening, missing or improperly integrated window flashing, inadequate or missing sill pan flashing, improper sealant application at frame perimeters — create infiltration paths for bulk water from wind-driven rain into the wall assembly; wall cavity water infiltration from window installation defects generates wood rot in framing members, insulation saturation, mold growth on sheathing and framing, and potential structural compromise — all recoverable as CLRA actual damages against the unlicensed C-17 contractor; the weather envelope breach track overlaps with the CLRA actual damages available under Health & Safety Code § 17920.3(a)(1) (dampness of habitable rooms from defects in construction or lack of adequate weather protection) as applied to window installation defects.

PURE KETCHUM for Bus. & Prof. Code § 7028 C-17 Glazing Contractor licensing violations: CPSC 16 CFR Part 1201 (Safety Standard for Architectural Glazing Materials) is a federal consumer product safety standard for glazing manufacturers and importers — it creates no private mandatory attorney fees for homeowners against unlicensed C-17 glazing installation contractors; the California Building Code Section 2406 safety glazing requirements are California administrative building code provisions creating building permit enforcement, not private mandatory fee statutes; the NFRC certification program is administered by a private nonprofit organization (National Fenestration Rating Council) — PURE KETCHUM on NFRC private standards; the CLRA § 1780 mandatory attorney fee entitlement against the unlicensed C-17 contractor is pure Ketchum; Ketchum v. Moses 24 Cal.4th 1122 (2001); PLCM Group Inc. v. Drexler 22 Cal.4th 1084 (2000); Hensley v. Eckerhart 461 U.S. 424 (1983); Missouri v. Jenkins 491 U.S. 274 (1989) fees-on-fees.

Primary Welch Anchor: Tyler Odyssey Civil Complaint Filing Date

The Tyler Odyssey civil complaint filing date is the primary Welch temporal anchor. In C-17 glazing matters, the attorney files after confirming the C-17 license status, conducting the CBC § 2406 safety glazing advisory (inspecting hazardous locations for CPSC marking presence or absence), conducting the CEC fenestration advisory (confirming NFRC label compliance for replacement windows), assessing weather envelope breach risk, quantifying all consumer damages (disgorgement + safety glazing replacement + window replacement if energy code non-compliant + water damage repair), confirming the CLRA § 1780 consumer predicate, and serving the CLRA § 1782 demand. The CSLB C-17 License Check date is the secondary Welch anchor from which all pre-complaint advisory hours accrue.

Secondary Anchor: CSLB License Check (C-17 Glazing Specialty) — THE ONLY C-17 Glazing Specialty Anchor in the Fee-Petition-Mechanics Series

The CSLB License Check must confirm the C-17 Glazing specialty — a B general building license does not authorize standalone C-17 glazing installation. Three status scenarios generate § 7028 liability: (a) no CSLB license of any kind; (b) B-license without C-17 for standalone glazing contracts; (c) expired, suspended, or revoked C-17 license. The C-17 License Check date is the secondary Welch anchor and this page is THE ONLY C-17 Glazing Contractor specialty anchor in the entire fee-petition-mechanics series.

Billing Gap 1 — CSLB License Check (C-17 Specialty), CBC § 2406 Safety Glazing Advisory, CEC Fenestration Advisory, Weather Envelope Assessment, and § 1782 Demand (5.25 hrs/yr = $1,575–$2,625)

The first billing gap covers pre-complaint advisory: C-17 licensing confirmation, CBC § 2406 safety glazing inspection advisory (CPSC marking presence/absence), CEC fenestration NFRC compliance advisory, weather envelope infiltration advisory, and CLRA § 1782 demand.

• Searching the CSLB License Check at cslb.ca.gov for the C-17 Glazing specialty and establishing the secondary Welch anchor: confirming C-17 specialty presence or absence; advising on B-without-C-17 scenario for standalone glazing contracts; confirming bond status for collection analysis.
• Conducting the CBC § 2406 safety glazing advisory — identifying all glazing installed in CBC § 2406 hazardous locations (shower enclosures, glazed doors, door-adjacent glazing, stairway glazing, railing glazing) and confirming the presence or absence of the required CPSC 16 CFR Part 1201 permanent safety glazing marking: the CBC safety glazing advisory generates pre-complaint hours for inventorying hazardous location glazing, confirming CPSC marking status, advising on immediate replacement necessity to eliminate premises liability, and quantifying replacement cost as CLRA actual damages.
• Conducting the California Energy Code Title 24 Part 6 fenestration advisory — confirming the applicable CEC climate zone, reviewing NFRC labels on installed replacement windows for U-factor and SHGC compliance, and advising on HERS Rater verification if required: the CEC fenestration advisory generates pre-complaint hours for identifying non-NFRC-documented windows, advising on compliance confirmation, and quantifying replacement window costs for non-compliant units.
• Conducting the weather envelope assessment — inspecting window frame installation for waterproofing membrane, sill pan flashing, and perimeter sealant adequacy, and advising on water infiltration risk from installation defects: the weather envelope assessment generates pre-complaint hours for evaluating infiltration risk and quantifying water damage repair costs if infiltration has already occurred.
• Quantifying § 7031(b) disgorgement and CLRA § 1780 actual damages (safety glazing replacement for CBC § 2406 hazardous locations, replacement windows for CEC non-compliant units, water damage repair from weather envelope breaches) and serving the CLRA § 1782 demand: residential window replacement contracts range from $3,000 to $30,000+; safety glazing replacement for shower enclosures and doors may add $500–$3,000+ per unit; water damage repair from infiltration may add $2,000–$20,000+.

Billing Gap 2 — Active Litigation: Glazing Expert, Water Infiltration Expert, Three-Track Harm Analysis, and Settlement Valuation (4.00 hrs/yr = $1,200–$2,000)

The second billing gap covers expert coordination across the safety glazing, energy code, and weather envelope harm tracks.

• Retaining a licensed C-17 glazing expert — to document the safety glazing deficiencies (CPSC marking absence in hazardous locations, annealed glass confirmation), the energy code non-compliance (NFRC label absence or non-compliant U-factor/SHGC), and the weather envelope installation defects (missing flashing, inadequate sealant) and quantify the complete remediation cost: the glazing expert must assess all three harm tracks and prepare a comprehensive remediation cost estimate covering safety glazing replacement, energy-code-compliant window replacement, and weather envelope repair.
• Coordinating the water infiltration and mold assessment — if weather envelope breach has generated wall cavity water infiltration, engaging a moisture/mold assessment professional to document the extent of damage and quantify the remediation scope (drywall removal, framing repair, mold remediation): water infiltration coordination generates litigation-phase advisory hours for integrating the infiltration/mold assessment into the CLRA damages narrative for Track 3.
• Analyzing the three-track harm — (Track 1) safety glazing injury risk and replacement costs; (Track 2) energy code non-compliance, HERS re-verification, and replacement window costs; (Track 3) weather envelope breach water damage and mold remediation costs — and integrating all three tracks into the CLRA § 1780 damages narrative: three-track integration generates litigation-phase advisory hours for expert coordination.
• Settlement valuation incorporating § 7031(b) disgorgement, CLRA § 1780 actual damages across all three tracks, and CLRA § 1780 mandatory attorney fees: the multi-track C-17 settlement demand generates advisory hours specific to the glazing specialty's unique three-track damages architecture.

Billing Gap 3 — CLRA § 1780 Fee Petition, Pure Ketchum Multiplier, Lodestar Documentation, and Missouri v. Jenkins Fees-on-Fees (4.00 hrs/yr = $1,200–$2,000)

The third billing gap covers fee recovery preparation across all three C-17 harm tracks.

• Documenting the CLRA § 1780 lodestar from the CSLB C-17 License Check date: capturing CBC § 2406 safety glazing advisory hours, CEC fenestration advisory hours, NFRC label review hours, weather envelope assessment hours, glazing expert coordination hours, and three-track damages analysis hours as CLRA § 1780 fee-petition-eligible work.
• Briefing the pure Ketchum multiplier: Ketchum factors: (a) contingency risk; (b) novelty/difficulty — CBC § 2406 safety glazing code analysis (CPSC marking confirmation in hazardous locations), CEC Title 24 Part 6 fenestration climate zone compliance, NFRC certification documentation review, three-track glass breakage/energy code/weather envelope damages integration; (c) results obtained; Ketchum v. Moses 24 Cal.4th 1122 (2001).
• Missouri v. Jenkins fees-on-fees for the fee petition: Missouri v. Jenkins 491 U.S. 274 (1989).

Total Annual Billing Gap — Three-Gap Summary

• Gap 1 (C-17 CSLB search, CBC § 2406 safety glazing advisory, CEC fenestration advisory, weather envelope assessment, § 1782 demand): 5.25 hrs = $1,575–$2,625/yr
• Gap 2 (glazing expert, water infiltration expert, three-track harm analysis, settlement valuation): 4.00 hrs = $1,200–$2,000/yr
• Gap 3 (CLRA § 1780 fee petition, pure Ketchum multiplier, lodestar documentation, fees-on-fees): 4.00 hrs = $1,200–$2,000/yr
• Total: 13.25 hrs = $3,975–$6,625/yr untracked at $300–$500/hr median California solo practitioner rate

Related California Attorney Fee Petition Pages

• California CSLB Roofing Contractor C-39 — Bus. & Prof. Code § 7028 (Weather Envelope)
• California CSLB Insulation & Acoustical Contractor C-2 — Bus. & Prof. Code § 7028 (CEC R-Value)
• California CSLB Lathing & Plastering Contractor C-35 — Bus. & Prof. Code § 7028 (Exterior Envelope)
• California CSLB Home Improvement Contract — Bus. & Prof. Code § 7159