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A certificate of insurance confers no rights on you, so a vendor checklist has to verify more than paperwork

Published May 25, 2026 · Updated September 3, 2026 · By Thrare Contracting

A property manager who signs an exterior services contract takes on three exposures that the vendor's paperwork does not transfer: damage to a substrate the crew was not qualified to clean, an injury on a property whose owner never confirmed what the vendor actually carries, and a discharge to a storm drain that the governing ordinance attributes to the property owner alongside the contractor. All three exposures are checkable before a crew mobilizes. None of the three is checked by collecting a folder of documents and filing it.

The exterior cleaning trade attracts under-qualified operators because the equipment barrier to entry is low, and the gap between a consumer-grade operator and a commercial contractor never appears on an invoice. This checklist is written for the person who signs the contract. Every item on it is verifiable from a public register, from a document issued by somebody other than the vendor, or from an answer the vendor gives on the phone in one sentence.

What does a certificate of insurance actually prove?

A certificate of insurance proves that a policy existed on the day the certificate was issued, and a certificate proves nothing else. Georgia writes that limitation into the certificate itself. The Rules of the Commissioner of Insurance, Georgia Administrative Code subject 120-2-103, require at rule 120-2-103-.05 that a certificate carry the statement: "This certificate of insurance is issued as a matter of information only and confers no rights upon the certificate holder. This certificate does not amend, extend or alter the coverage, terms exclusions and conditions afforded by the policies referenced herein."

Read that sentence as a procurement instruction rather than as boilerplate. The certificate is evidence of a policy. The certificate is not the policy, cannot enlarge the policy, and gives the organization named on it no claim against the insurer. A property manager who has collected a certificate has confirmed that a policy was in force on an issue date and has confirmed nothing about what that policy covers, whom it covers, or whether it is still in force this morning.

Rule 120-2-103-.04 defines the two roles precisely. A "certificate of insurance" is any document issued by an insurer or a producer as evidence of property or casualty insurance coverage, and a "certificate holder" is any person other than a policyholder who requests or possesses a certificate. Rule 120-2-103-.02 states the purpose of the subject as establishing guidelines, procedures and best business practices for the issuance and delivery of property and casualty certificates of insurance in the State of Georgia. Rule 120-2-103-.05 also permits shorter wording on limited-use certificates: "This certificate of insurance does not amend, extend, or alter the coverage, terms, exclusions, and conditions afforded by the policies referenced herein."

Two practical consequences follow for a vendor file. First, a certificate issued by the contractor rather than by an insurer or a producer does not meet the definition in rule 120-2-103-.04, so a certificate that arrives as a screenshot from the vendor's phone is worth a call to the producer named on it. Second, if the contract requires additional insured status, the certificate is not the thing that grants it. The endorsement is.

What is the difference between a certificate holder and an additional insured?

A certificate holder receives a copy of a document; an additional insured is added to the policy by endorsement and has standing under it. Those are different legal positions and a certificate lists them in different boxes. Requiring additional insured status in the contract and then accepting a certificate that names the organization only as certificate holder leaves the file looking complete and the position unchanged.

When requesting a certificate, give the vendor the exact legal name of the entity to be named and the address as it should appear, in writing, before the vendor contacts the producer. Ask separately for the additional insured endorsement itself, by form number, not for a certificate that references one. Endorsement wording controls scope, and wording that grants status only for work performed by the named insured reads differently from wording that grants status for ongoing and completed operations.

Certificate conditions worth a second look before the crew is scheduled:

Why does a missing W-9 become the payer's problem rather than the vendor's?

A missing or incorrect taxpayer identification number shifts an obligation onto the party writing the check. According to the Internal Revenue Service, "There are situations when the payer is required to withhold at the current rate of 24 percent." The Internal Revenue Service places that duty on the payer under the BWH-B program where the contractor "failed to provide a correct taxpayer identification number (TIN) to the payer for reporting on the required information return."

Read in the direction that matters to a management company: an unreturned Form W-9 is not a gap in the vendor's file, it is a withholding obligation on the property's own accounts payable. The Internal Revenue Service describes Form W-9 as the way a payee provides a correct Taxpayer Identification Number to the person required to file an information return reporting, among other categories, income payments. Note the direction of travel. The contractor furnishes the W-9 to the requester, and the contractor does not file it with the Internal Revenue Service, so waiting until January to chase one is waiting until after the exposure has already run.

The operational rule is short. Collect the signed W-9 with the executed contract, before the first invoice is approved, and re-collect it whenever the vendor changes entity type, legal name or taxpayer identification number. The 24 percent figure is the current rate the Internal Revenue Service publishes; the rate has changed by statute before, so a management company writing a vendor policy should cite the agency rather than a fixed number.

Can a property owner be held responsible for a contractor's wash water?

Yes, and at least one metro Atlanta county publishes that answer to consumers in plain words. Gwinnett County Water Resources, in its brochure "A Consumer's Guide to Hiring a Pressure Washing Contractor", tells property owners: "Keep in mind that as the consumer, you may also be held responsible for illegal discharges that occur on your property." The county's technical guideline says the same thing from the other direction. Water Quality Protection Guideline WQ-1, "Surface Cleaning", dated 04/05/2007, states at 3.1(11) that "As the generator of the washwater the surface cleaner is considered jointly responsible with the property owner for its appropriate disposal."

The federal rule underneath all of this is a definition, not a slogan. 40 CFR 122.26(b)(2) defines an illicit discharge as "any discharge to a municipal separate storm sewer that is not composed entirely of storm water except discharges pursuant to a NPDES permit (other than the NPDES permit for discharges from the municipal separate storm sewer) and discharges resulting from fire fighting activities." Wash water from exterior cleaning carries sediment, oil and grease, and detergent, so wash water reaching a storm drain is a non-stormwater discharge by definition.

Local ordinance is what a code enforcement officer actually writes against, and the governing instrument changes with the property line. For a property inside the City of Atlanta limits, Atlanta City Code section 74-436 states: "No person shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the storm sewer system of the City of Atlanta any pollutants or waters containing any pollutants, other than stormwater." Section 74-429 applies the article throughout the corporate limits of the City of Atlanta, and the definition of pollutant in section 74-428 expressly names detergents, "biodegradable or otherwise", along with degreasers and cleaning chemicals.

Penalty figures do not travel between jurisdictions, and quoting one from the wrong county is how a vendor policy loses credibility. Gwinnett County's Illicit Discharge and Illegal Connection ordinance states at Sec. 100-27(f): "Upon conviction, such person shall be punished by a fine not to exceed $1,000.00 or imprisonment for 60 days or both. Each act of violation and each day upon which any violation shall occur shall constitute a separate offense." That figure belongs to Gwinnett County's ordinance and to nothing else on this page. Sec. 100-21(e) of the same ordinance limits the article to the unincorporated area of the county, so the number does not reach an address inside Lawrenceville, Duluth, Snellville or any other incorporated Gwinnett city, and it has no application at all in Cobb, DeKalb or Fulton, each of which runs its own instrument. A property manager writing a portfolio-wide vendor standard cites the rule and lets each property's own ordinance supply the number.

What should a vendor be able to tell you about wash water before the crew arrives?

A qualified vendor can name the dry cleanup step, the containment method and the disposal point without being prompted, and can do it on the phone. Gwinnett's WQ-1 guideline puts the screening duty on the buyer directly: 3.1(4) says a buyer "should ensure that the selected contractor is capable of completing surface cleaning in accordance with this guideline". The guideline was developed in cooperation with the Power Washers of North America, so the answers below are the trade's own, not a regulator's invention.

Four answers separate a vendor who has read the guideline from a vendor who has not:

The narrow exception is worth knowing because vendors misquote it. WQ-1 3.2.1.4 permits discharge to a storm drain only when every one of its criteria is met, including no detectable pollutants, no visible or known contaminants on the surface, pH between 6.0 and 8.5, temperature not exceeding 90 degrees F, conductivity below 300 uS/cm, fecal coliform under 150 cfu/100 mL, screening and draining through an oil absorbent berm, and no grassy-area option available. The guideline then states at 3.2.1.4(4) that "This disposal option is intended to allow for cosmetic cleaning of surfaces stained with leaves, mildew, or atmospherically deposited dusts and pollens only." A fuel bay, a dumpster pad and a drive lane are none of those things. Where a grassy discharge is used instead, 3.2.1.3 requires a minimum separation of 50 feet between the discharge point and the nearest storm drain or waterway, sheet flow with no runoff, and dry weather.

Gwinnett County also maintains a register a manager can consult. Section 4(2) of WQ-1 records that the county "has established a 'List of Businesses Capable of Collecting Surface Cleaning Washwater.'" Operators apply on Form WQ-1c, are required to demonstrate the capabilities of their equipment, and the list is supplied to the public, though inclusion "does not constitute an endorsement of the operator by the county." Rare Earth Ltd is not on that list, and a manager screening vendors for a Gwinnett property should treat the list as one input rather than as the whole test.

Which pressure numbers separate a competent vendor from a confident one?

A vendor who quotes a single pressure for an entire building has not read the substrate literature, because the published ceilings differ by cladding and are written by different organizations that do not agree with one another. Ask which document governs the cladding on the property, and ask whether a trial area will be cleaned first. The answers are checkable.

For brick, the Brick Industry Association states in Technical Notes on Brick Construction 20, "Cleaning Brickwork", August 2018 edition: "Do not use water pressures higher than 400 psi (2800 kPa) as measured at the nozzle tip unless permitted by brick manufacturer". The same document states that "High-pressure water cleaning is not appropriate for brick and may damage the brickwork", directs the operator to use a stainless steel 25 to 50 degree fan tip held a minimum of 12 inches from the brick surface, and calls for a trial cleaning on a 20 square foot sample area with the wall allowed to dry before results are evaluated.

For fiber cement, the manufacturer sets the limit for its own product. James Hardie Building Products, in Technical Bulletin #20, November 2018, states that using "wide fan tips that are kept a minimum of 6 feet from the wall and at pressures under 1500 psi will minimize the chance of damaging the siding", records that sand blasting and acid washing are not recommended, and adds that damage arising from improper cleaning or maintenance may not be covered by the James Hardie warranty. That warranty sentence is the one a property manager should note, because a cleaning method chosen by a vendor can move a repair cost onto the owner.

For EIFS and acrylic stucco, two manufacturers converge on a much lower number. Sto Corp., in its StoTherm EIFS Reference Guide for repair and maintenance, instructs the operator to keep pressure at approximately 200 to 500 psi and states: "Do not exceed 500 psi (1.4 MPa) pressure, as the EIFS surface integrity can be destroyed with higher pressure washing." Sika Corporation's Senergy technical bulletin on cleaning finish and removing efflorescence, revised February 2024, states: "Never use water pressure more than 500 psi or allow pressure nozzles to come within 2 feet of the wall", specifies fan type tips of 30 to 45 degrees or greater, and adds the sentence that settles most arguments on a job site: "The chemicals provide the cleaning, not the water pressure."

Carry two caveats into any vendor conversation about these numbers. The Brick Industry Association is a trade body and James Hardie, Sto and Sika are manufacturers writing for their own products, so none of the four documents is a regulation. And no figure crosses to a cladding its document does not name: a 1500 psi fiber cement ceiling is not a brick figure, and a 500 psi EIFS ceiling is neither. A building with mixed cladding needs a method per elevation, written into the scope.

Does Georgia require your vendor to carry workers compensation?

Georgia sets the threshold at three. The Georgia State Board of Workers' Compensation states in its employer information that "Every employer, individual, firm, association, or corporation, regularly employing three or more persons, part-time or full time, shall provide workers' compensation insurance coverage." The Board adds that "Exempted officers of corporations or exempted members of limited liability companies shall not reduce the number of employees for this purpose."

That statement is the statutory floor for any Georgia employer, and a statutory floor is not a procurement standard. A property management company is free to require a specific status in its own contract regardless of how many people a vendor employs, and many do. What a manager should not do is read the absence of a workers compensation line on a certificate as a paperwork oversight; the absence is information, and the right response is a question to the vendor rather than an assumption in either direction.

How does a manager confirm that a vendor is a current, registered business?

The Georgia Secretary of State's Corporations Division record is the register, and the annual registration filing is the currency test. Georgia Administrative Code rule 590-7-4-.03(1) provides: "Each corporation that is on file with the Secretary of State and registered to do business in this state shall, between January 1 and April 1 of each year, file an annual registration with the Commissioner." Rule 590-7-4-.03(2) adds that the annual registration is due as of January 1 of any calendar year in which a corporation exists or is qualified to transact business in the State of Georgia.

Rule 590-7-4-.10 states the consequence: "A corporation that is on file with the Secretary of State or authorized to transact business in this State that fails to file its annual registration with the correct fee may be subjected to administrative dissolution or revocation in accordance with the provisions of Title 14 of the Official Code of Georgia Annotated." Note the verb. Administrative dissolution is stated as something an entity may be subjected to, not as an automatic result, so a lapsed filing is a flag to raise with the vendor rather than a finding that the company no longer exists.

Two things this check does not do. Subject 590-7-4 governs corporations, and limited liability companies file under a parallel subject, so a manager reading a vendor's record should confirm the entity type before comparing it against the wrong rule. And a state annual registration is not a business license and not a local occupational tax certificate; a city or county issues those separately, and the two are routinely treated as one item on vendor checklists that were never checked against the source.

Certification claims deserve the same treatment. Verify a diversity certification in the certifying body's own record rather than from a letter the vendor forwards, because a letter shows a status on the day it was issued and a directory shows the status today. Federal registration is public: an entity registered in SAM.gov can be looked up by its Unique Entity ID, and a property manager working on a federally funded property can confirm registration status without asking the vendor for anything. Our page on MBE and DBE pressure washing lists what documentation we send.

What should you actually ask a vendor's references?

References are the most collected and least used item in commercial vendor qualification, because a reference asked whether it was happy with the work will say yes. Ask instead for three references from commercial clients in a comparable property category, office, retail, multifamily or industrial, at a comparable service scale. A residential cleaning company that has handled a few commercial jobs is not the same reference as a company with a standing commercial account base, and the difference shows up in the answers rather than in the list.

Five questions that produce a usable answer:

Ask for a before and after photograph set from comparable commercial projects at the same time. A vendor who cannot produce one either does not document the work or does not have commercial work to document. Photographs also show whether the vendor knows what a finished commercial surface looks like, because results that pass a walkthrough in the field frequently photograph as partially cleaned.

What belongs in the written scope, and what belongs in the exclusions?

A written exterior scope names surfaces by type and approximate area, names a method for each surface, and lists what the price does not include. A verbal agreement or an email thread is a starting point for an argument, not a contract, and the argument always happens at the invoice. The exclusions list is the half most contracts omit and the half that prevents the dispute.

Scope elements that belong in writing for commercial property work:

Exclusions that belong in the same document, because each is regularly assumed into an exterior price and is not in one: painting, caulking and sealant work, siding or panel replacement, roof cleaning, the interior of gutters and downspouts, window cleaning above the ground floor, sealcoating and pavement striping, gum and graffiti removal where not itemized, any work requiring a permit or a lane closure, and any handling or characterization of waste that is not ordinary surface cleaning washwater.

What documentation should a manager require after each visit?

Documentation is what turns an exterior service into a defensible record for common area maintenance reconciliation, for a lender inspection, and for a liability question raised eighteen months later. Setting the requirement in the contract costs nothing; adding it after an incident is not possible. Four records cover most portfolios.

For a Gwinnett County property there is a fifth record the county itself designed. WQ-1 section 3.4 describes a Pollution Prevention Voucher, Form WQ-1d, one per job site, printed in duplicate with one copy given to the customer and kept at least one year. The guideline records the voucher as recommended rather than required and states that a copy "should not be submitted to Gwinnett County", so the voucher lives in the property file, which is exactly where a manager wants it.

What does Thrare Contracting document on request?

Thrare Contracting is a minority-owned commercial exterior services company operating from 8735 Dunwoody Pl, Ste R, Atlanta, GA 30350. Rare Earth Ltd carries general liability insurance, and this page makes no claim about any other line of coverage. The certificate itself is the document, issued by the producer and subject to the same rule 120-2-103-.05 statement quoted at the top of this page.

Documents we send with a vendor packet, without being asked twice:

To request that packet with a written estimate for a specific property, see our commercial pressure washing page or call (678) 748-3578.

Vendor qualification checklist

  1. Certificate of insurance received directly from the insurer or producer, not from the contractor
  2. Additional insured endorsement obtained by form number where the contract requires that status, rather than a certificate that references one
  3. Certificate expiration date confirmed to fall outside the service period, with a renewal scheduled
  4. Signed Form W-9 on file before the first invoice is approved
  5. Georgia Secretary of State entity record checked, with the annual registration current and the entity type noted
  6. Local business license or occupational tax certificate confirmed separately from the state record
  7. Workers compensation status confirmed against the Georgia State Board of Workers' Compensation threshold and against the contract's own requirement
  8. Wash water containment method and disposal point stated by the vendor and written into the scope
  9. Substrate method confirmed against the document that governs the cladding, with a trial area agreed
  10. Diversity or federal certifications verified in the certifying body's own record, not from a forwarded letter
  11. Three commercial references contacted, with a specific question about how the vendor handled a problem
  12. Written scope, exclusions list, change order process and damage reporting window executed before mobilization
  13. Documentation standard agreed: photographs, completion record, service log, safety data sheets

Frequently asked questions

Does a certificate of insurance give a property manager rights under the vendor's policy?

No. Georgia Administrative Code rule 120-2-103-.05 requires a certificate to state that it "is issued as a matter of information only and confers no rights upon the certificate holder" and that it "does not amend, extend or alter the coverage, terms exclusions and conditions afforded by the policies referenced herein." Rights under a policy come from an endorsement adding the organization as an additional insured, so a manager whose contract requires that status should request the endorsement by form number rather than accept a certificate that mentions one.

What is the backup withholding rate if a contractor does not provide a W-9?

The Internal Revenue Service states that "There are situations when the payer is required to withhold at the current rate of 24 percent", and applies that duty under the BWH-B program where the payee failed to provide a correct taxpayer identification number to the payer for reporting on the required information return. The obligation falls on the payer, which for a property is its own accounts payable, so a signed Form W-9 belongs on file before the first invoice rather than at year end.

Can a property owner be held responsible for a contractor's wash water discharge?

Yes. Gwinnett County's consumer guide to hiring a pressure washing contractor tells owners: "Keep in mind that as the consumer, you may also be held responsible for illegal discharges that occur on your property." Gwinnett's guideline WQ-1 states at 3.1(11) that the surface cleaner is considered jointly responsible with the property owner for appropriate disposal of the washwater. The instrument that applies at a given address is the local ordinance, so a portfolio standard should cite the rule and let each property's own ordinance supply any penalty figure.

What water pressure is safe for brick, fiber cement siding and EIFS?

Three different documents give three different ceilings. The Brick Industry Association, in Technical Notes on Brick Construction 20, August 2018 edition, says not to use water pressures higher than 400 psi as measured at the nozzle tip unless the brick manufacturer permits it. James Hardie Technical Bulletin #20, November 2018, says wide fan tips kept a minimum of 6 feet from the wall at pressures under 1500 psi minimize the chance of damaging its fiber cement siding. Sto Corp. and Sika both cap EIFS and acrylic stucco at 500 psi. No figure carries across to a cladding its own document does not name.

How does a property manager confirm a Georgia contractor is still a registered business?

Check the Georgia Secretary of State Corporations Division record for the entity. Georgia Administrative Code rule 590-7-4-.03(1) requires each corporation on file and registered to do business in the state to file an annual registration between January 1 and April 1 of each year, and rule 590-7-4-.10 provides that a corporation failing to file with the correct fee may be subjected to administrative dissolution or revocation under Title 14 of the Official Code of Georgia Annotated. The state annual registration is separate from a local business license or occupational tax certificate, which a city or county issues on its own schedule.

Does Georgia require every contractor to carry workers compensation insurance?

No, Georgia sets a threshold. The Georgia State Board of Workers' Compensation states that every employer, individual, firm, association, or corporation regularly employing three or more persons, part-time or full time, shall provide workers' compensation insurance coverage, and that exempted officers of corporations or exempted members of limited liability companies do not reduce the employee count for that purpose. A property management company may still require a specific status by contract regardless of the statutory floor.

Sources

Commercial property standards from BOMA (Building Owners and Managers Association).

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