Specifically, the Board should review the American Society for Quality’s (ASQ) website (www. asq.org) for examples of how the ASQ recertifies quality engineers and inspectors. ASQ allows credit for actively working in the quality field, authoring papers, participating in committees and attending professional/technical society meetings to meet their recertification requirements, and the Commonwealth of Virginia should incorporate a similar allowance into their regulations.

 

Currently, there is no requirement to work in the engineering field to maintain experience as an engineer for renewal of the Professional Engineer’s license. Clearly, a Professional Engineer working as a personal financial planner or insurance salesman will have a different continuing education need than a Professional Engineer actively engaged in the engineering profession. Yet, the proposed regulations do not recognize this key difference. Actively working in the engineering field will help “sharpen the saw” on a daily basis, and professional engineers should be given some credit for this employment in meeting the continuing education activity requirement. The ASQ allows employment in the quality field to be used to meet 60% of their recertification requirements.

 

Authoring or co-authoring technical papers, books or technical/professional society presentations requires significant, in-depth, current technical knowledge of the subject area and is of benefit both to the Professional Engineer that authors the work but also to the larger community of Professional Engineers for their educational benefit. Consistent with what the proposed regulations allow for credit for preparing training, the regulations should allow credit for authoring technical papers, books or presentations.

 

Participation in professional/technical society meetings, committees, and conferences is used by many Professional Engineers to stay abreast of current technical issues in the profession and the proposed regulations should allow some continuing education activity credit for this type of activity.   Most professional/technical society conferences have several sessions where engineers present their technical papers and “train” the audience and this should be creditable for the continuing education activity requirements.

 

b. The proposed regulations should be revised to delete the requirement to maintain records of completion of continuing education activities for three years from the date of expiration of the license for which the continuing education activities are being used for renewal. (Part XII, Standards of Practice and Conduct, paragraph D.2.)

Specifically, the proposed requirement is arbitrary, capricious, adds no value to the protection of the public, adds additional unnecessary burden to Professional Engineers, and unnecessarily extends the Board’s authority to audit records for expired licenses without legal basis. As written, the proposed regulation would require Professional Engineers to maintain records of continuing education activities for up to seven years past the completion date of the activities and allow the Board to audit back seven years for a license that has been expired for three years. The Board’s ability to audit continuing education requirements should be strictly limited ONLY to active licenses and license renewal applications. Why does the Board feel that it needs to be able to audit requirements for expired licenses? What would the board do if it had concerns with the continuing education requirements for an expired license? The Board, for the benefit of the public, needs to limit their auditing of records to current licenses and license renewals and not waste the taxpayer’s money auditing records for expired licenses. The requirement as written makes no sense and is an unnecessary burden on the Professional Engineers without any benefit to the public.  

Incorporating these comments into the proposed regulations will reduce the burdens on Professional Engineers relative to continuing education while meeting both the intent and spirit of the law as passed by the General Assembly.

 

Todd Bockwoldt, PE