Further to our featured article ‘Severe Penalties for RPEQ Non-Compliance’ in December’s edition of Technology Update, the Board of Professional Engineers of Queensland (‘BPEQ’) has published further articles subsequent to receiving a number of comments and questions regarding aspects of its original publications released late last year.
In response to feedback the articles explain in detail the standards of ‘provision of engineering services’. Three clarifications have been summarised as follows:
1. Professional engineering services undertaken outside of Queensland for Queensland projects:
“A person carrying out professional engineering services outside of Queensland, for projects based in Queensland, must be an RPEQ or be working under the direct supervision of an RPEQ.”
This item suggests that engineering design performed on overseas packaged equipment needs to be by RPEQs, unless such activity is not a professional engineering service which seems unlikely in most cases. What RPEQ supervisory provisions do you have in place? If you are relying on RPEQ for direct supervision, what does this mean in terms of contractual responsibilities?
2. Direct Supervision by RPEQ:
“……. the RPEQ must, in the role of the supervisor: (a) have sufficient knowledge of the professional engineering services carried out; (b) sufficient control over any outputs of the professional engineering services to reasonably form the view that the standard of the professional engineering services is that to be expected of an RPEQ; and (c) take full professional responsibility for the professional engineering services provided by that person.”
In practice, this means:
a) the supervision must be direct; and
b) the supervising RPEQ must direct the person in the carrying out of the service; and
c) the supervising RPEQ must oversee the carrying out of the service by the person; and
d) the supervising RPEQ must evaluate the carrying out of the service by the person; and
e) the supervising RPEQ must take full professional responsibility for the service.
The supervision must be direct. The supervisor must have direct contact with the supervisee and actual knowledge of the professional engineering service being provided. Depending on the nature of the service being supervised, direct contact need not be in person, but may be through written correspondence (letters, drawings, or emails), telephone, or voice or video chat. However, the contact must be directly between supervisor and supervisee, and not through a third person.
3. Professional engineering service versus Prescriptive standard:
“The Board takes the view that a person who merely undertakes tasks set out in, or required by, a document which meets the definition of ‘prescriptive standard’, is providing services ‘only in accordance with’ a prescriptive standard. That person is therefore not providing ‘professional engineering services’ and does not need to be registered. A document can meet the definition of ‘prescriptive standard’ irrespective of whether it is published by a body such as Standards Australia, or is produced by an individual RPEQ engineer for application in particular circumstances.
On the other hand, where a person provides services which include, for example, a professional decision to use a particular document which states procedures or criteria, that service is unlikely to be ‘provided only in accordance with ‘a prescriptive standard’. That is because the decision to use the document is unlikely to be a decision taken in accordance with the document itself. A service which includes a professional judgment about which standards or criteria should be applied to a particular situation is therefore likely to be a ‘professional engineering service.’”
Titan ICT will continue to keep you updated, and importantly we are happy to work with Engineering Managers across the Industry to ensure we remain compliant.
The published updates: Practice Note Series – Direct Supervision and Practice Note Series – Prescriptive Standards, can be accessed at the BPEQ website.