Sir:

Given that the General Assembly has passed a statute requiring continuing education (silly, but I did not choose to rule as a legislator, and therefore my wishes are irrelevant), I wish to address the fact that certain engineers work specialized jobs that are not condusive to standard training.  For example, given that my job is to perform design instructions for CERCLA cleanup work on radiologically and beryllium contaminatedfacilities and Operable Units, the Board needs to come to terms with the fact that training that is available for a given job may not be standard. 

In particular, my OU ARARs require completion of work per removal action work plans, air monitoring plans, and associated rstate and federal regulations.  Usually, updates of these requirements are made via meetings with regulators.  Additionally, tribal cleanup scenarios are briefed on regular bases during Risk Assessment planning activities.  None of these requirements are condusive to obtaining typical training, and none of it is available on a standard CEU basis.  In the cases above, training is documented at best by a roster and an agenda, kept in the central training office.

Additionally, federal employees are required, in some agencies, to obtain very specific ethics training.  In my case, 5CFR2634 Subpart I requires very specific annual training that is developed in house by Department of Energy legal staff.  There is no mechanism at all to have this training material available for the Board to review.

I would also submit that in times of tight discretionary federal budgets, training that does not directly effect the agency's mission will not be approved.

In short, the CE requirement could be addressed by having associated engineers certify, via use of their stamp if necessary, that the sum total of regulatory briefing, law updates, ethics traing, etc, would constiture 16 hours over the lecense period. 

Thank You for your time.

R. F. Guercia, PE