Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects
 
chapter
Board for Architects, Professional Engineers, Land Surveyors, Certified Interior Designers, and Landscape Architects Regulations [18 VAC 10 ‑ 20]
Action Develop regulations for a mandatory continuing education requirement for architect, professional engineer, and land surveyor licenses.
Stage Proposed
Comment Period Ended on 5/2/2008
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3/10/08  2:30 pm
Commenter: Scott C. Flieg, PE DON - Naval Reactors

The Law is the Problem - Not Necessarily the Proposed Regulation
 

If I have reviewed this properly, it seems the state legislature passed a law in 2006 requiring the Board to instigate CE requirements ( http://leg1.state.va.us/cgi-bin/legp504.exe?061+ful+CHAP0683 ).  I highly recommend that anyone that disagrees with this law contact their state representatives and the governor with their concerns.  Currently, it seems that the Board has no choice in the matter, except perhaps on defining some of the details that define what counts as CE and the administrative burdens to track it.

Although I often attend classes on various engineering and project management topics at work (though who knows if they would be "board-approved"), I think requiring CE as delineated by the law would add considerable bureaucracy and burden and have little real impact on the performance of PEs.   Many others have listed the additional, quantifiable burdens of CE to the PE: cost, time, admin. documenting and record keeping,  not to mention administrative burden on the board in certifying training, reviewing, and resolving disputes.  Whose engineering product will quantifiably improve?

Comments on the Proposed Regulation

1. 18-VAC10-20-683 par. B states that the 16 hours must be of "board-approved continuing education activities."  The following paragraph implies that if the criteria of paragraphs C.1-5 are met, the activity is approved.  Nowhere that I saw says their will be a predefined, approved list, or that pre-approval is necessary (good).  Clearly the Board applies the criteria, the question is how.  To reduce burden on the Board and on PEs, a course attended by, say, 10 PE's who each believe the course meets the criteria, should not be allowed to be "vetoed" by the Board.

2. The regulation states if audited, a PE must provide proof of CE activities completed.  It is unclear what the resolution process is if the proof provided is considered inadequate.

3. 18-VAC10-20-683 par. C.5.d:  Self-study without a "sponsor" of a topic meeting the criteria should be allowed for some fraction of the CE hours.  However, this section should state what information should be recorded to document the study (e.g., hours, date(s), text).

4. A sub-paragraph under 18-VAC10-20-683 par. C should address education activities via the internet, defining what should be required to document such study.  

5. Although not allow by the law, I would prefer the option to re-take the PE exam vice CE at some interval, perhaps every 10 years - if it doesn't test what you should know to be a PE, what good is it?

 

CommentID: 981