Recent articles about the industrial exception in Engineering Dimensions prompt me to share my views.
With all due respect, we (PEO) have given an incomplete and simplistic depiction of the industrial exception situation to the press and may even have tended to trivialize it. It is not an issue of the design of guards and personnel safety on machines making widgets or “dangerous” common machine shop tools.
In Ontario, we have a large number of industrial employees, many of whom have the credentials to qualify for membership and do engineering as described by the Professional Engineers Act but shun membership. Engineering is also done by employees who would not be eligible for PEO membership. I would suggest that the vast majority of PEO members who work as employee engineers do so because membership gives them attractive resume credentials in the event they get “downsized.” Their jobs do not require membership and they work side by side with licensed and non-licensed folks doing the same work.
The reality is that large companies have internal engineering divisions and departments staffed with managers, supervisors and folks doing engineering that do not follow the practices and rigour that a Certificate of Authorization firm would if it did the exact same work for the “client” company for a fee. Does this protect the public? How, then, does PEO exercise its regulatory mandate? To my mind it does not and with the industrial exception it cannot.
Exempt in-house engineering is not limited to simple machinery and equipment to make products. One industry example: petroleum/petrochemical/refining involves the engineering of complex chemical processes, piping systems, safety shutdown systems, and systems that treat effluent or mitigate environmental impacts. If the standards, checks and procedures and qualifications (competence) in-house are less than those offered by an engineering firm offering the same services to that industry, public protection may well be compromised.
With carbon tax and cap and trade regulations imminent, exempt folks will engineer changes to “their employer’s facilities.” How will PEO fulfill its mandate to protect the public? Perhaps PEO should concentrate on regulating, disciplining and assuring the competence of those individuals and firms that provide engineering services to the public and pass the responsibility for industrially exempt engineering to the province. After all, it is the province that has legislated the exception. PEO can then be called upon by the province as an advisor in this matter if they deem it necessary.
Elio Comello, P.Eng., Camlachie, ON