I have been a professional engineer since 1997.  Strictly speaking, I have not needed this certification in fulfilling my responsibilities.  However, I view it is a good-faith sign to our customers that I am sufficiently skilled technically in my field.  My company views it the same way and encourages our young employees to pursue certification.

I agree with the concept of continuing education as a means to ensure that licensed engineers remain current.  However, given the many disciplines—and many more specialties—represented by the commonwealth's engineers, achieving the goal of the legislation is a substantial challenge to say the least.

The proposed regulation provides little confidence that this challenge will be met.  The benefit of the continuing education requirement will hinge on the details of the implementation—yet the proposed regulation provides little insight as to how this requirement will really be fulfilled by individuals whose responsibilities are far more varied than many people likely realize.  I fear that many good-faith attempts on the part of PEs to fulfill the requirement will not be approved without a more concrete definition of what will be acceptable to the board.  If that were to happen to one or a couple of my firm's staff, it would be a very strong incentive for us to drop our licenses.

Given the difficulty in ensuring that approved courses/conferences/activities actually meet the intent of the law, I recommend either that:

1. The board provide a clearly defined list of courses that will be approved in the regulation (and that efforts are undertaken to ensure such courses are available regularly),
2. The board demonstrate substantial flexibility in approving different courses or conferences through clear language to this effect, or
3. The requirement be narrowed to cover only those who actively work in fields that directly impact public health and safety (coupled with 1 or 2 above).

Option 3 may be too difficult to implement, but would perhaps best meet the law's intent (and would allow more focused course requirements).  Option 1 apparently matches what some other states do and would be reasonable if implemented well.  Option 2 would mean that most anyone who wants to renew will be able to achieve it.  But isn't that the case now?  At least in this case (Option 2) a modest fraction (perhaps more) of the PEs would treat the requirement seriously and achieve a real benefit, and that's about the most that can be hoped for.  Leaving a lot of doubt about what will be approved for credit (as is currently the case) is not a credible approach.