I understand that the time to vote against HB1054 is long since past and that the purpose of this comment period is to discuss APELSCIDLA implementation of HB1054.

 

In reviewing the posted comments and Mr. Zdinak’s comments in the VSPE monthly electronic newsletter for April 2008, it is obvious that this issue is evoking strong emotion from the Professional Engineering community. Indeed, it is difficult to respond without feeling some level of anxiety and fear with regard to the verbiage as presented.

 

Firstly, I suggest that some clarification is required between 18VAC10-20-683 “Continuing Education Requirements for Renewal or Reinstatement” Section B which states that “individuals are required to complete at least sixteen continuing education credit hours of board-approved continuing education activities for any license renewal or reinstatement” and Section C.5.c which states “One semester credit hour of approved college credit shall equal 15 continuing education credit hours.” The one hour shortfall implies that two semesters will be required every two years and that any extra credit hours will not carry over into the next period as per Section D.1. Was the disconnect between Sections B and C intentional or is there a typographical error between these two sections?

 

My next item may provide some challenges with regard to proper legislative verbiage and implementation of bureaucratic oversight; however, I think it merits consideration. The current wording does not appear to provide the award of continuing education credit for the publication of technical papers. The publication of technical papers provides the opportunity for senior Professional Engineers to pass real, job-related, technical information to junior Professional Engineers and the technical community at large. Likewise, junior Professional Engineers who may have more current knowledge can pass their “newer” techniques on to more senior Professional Engineers and the technical community at large. 

 

By allowing continuing education credit for the publication of technical papers, the Commonwealth would foster the transfer of pertinent technical knowledge. The award of Professional Development Hours for publishing technical papers is allowed under North Carolina’s Continuing Professional Competency rules and as such is not without precedent. Credit award for the publication of technical papers will also provide relief to the possible burden upon the education system that may result from this legislation. Over the course of a 40 year Professional Engineering career, under the dictates of the proposed wording, two semesters of continuing education courses will be required every two years. The result is that 40 continuing education activities related to practice of the profession will be required over the time span of the career. Unless the Professional Engineer is willing to repeat courses, it is unlikely that suitable courses will be found to support the span of the career. I do not believe that the legislature is endorsing Professional Engineers take the same limited number of courses over and over again. I recommend adding verbiage to allow the publication of technical papers to be included in the award of continuing education credit.

 

While “self directed continuing education activity” is allowed, it is structured to be a risky activity because the award of credit is not assessed until the conclusion of the activity. In a traditional course, the credit will be determined prior to the start of the course and the attendee is responsible for fulfilling the requirements of the course in order to obtain the credit. For self directed continuing education activity, the award of credit is at risk until the conclusion of the activity. Clearly, few would elect to take a risky self directed activity. I recommend some revision of the verbiage for self directed continuing education activity to include criteria for acceptance and the identification of the resources which will approve such activity.

 

I believe that a large amount of the stress induced as the result of HB1054 can be traced to the rather restrictive terminology used in describing the “board-approved continuing education activity.” Mr. Zdinak states in the April electronic newsletter: “there are many opportunities out there from your professional society, technical societies, employer, and industry to provide specific, relevant training opportunities for less than $50 per PDH – many of these are, in fact, FREE.” As the technical director for a 20-person naval architecture and marine engineering company, I can assure you that I am continually looking for technically relevant training activities for the engineers in my staff. It is rare that I find “specific, relevant training opportunities” and none of them are free and, to my knowledge, none are “board-approved.”  What are the requirements to become “board-approved?” Does the board have the resources to engage in the approval of various continuing education activities? Will the board be delegating approval down to another organization? I suggest that VSPE or APELSCIDLA provide some examples of courses that meet the requirements of the continuing education activity. Hopefully, these examples would alleviate the stress and anxiety expressed in a number of the comments posted to this web site.

 

Lastly I would like to point out that the previous versions of the proposed legislation closely mirrored North Carolina’s Continuing Professional Competency rules which have been in place for a number of years. The current version of the legislation has digressed wildly from the previous versions. This digression appears to be the cause for the emotion in a number of the comments posted. Hopefully, addressing the concerns listed above will alleviate some of the emotion that has been evoked.

 

Thank you for your time and consideration in this matter.

 

With best regards,

 

Dean Schleicher, P.E.