PEO responds to the fairness commissioner on mandatory Canadian experience

While acknowledging that PEO’s 12-month Canadian work experience requirement for all applicants for licensure may not strictly comply with the provisions of the Fair Access to Regulated Professions and Compulsory Trades Act, the association expressed confidence to the Office of the Fairness Commissioner (OFC) that the requirement is necessary when considering its legislated mandate to protect the public interest.

Currently, all applicants wishing to obtain their licence to practise engineering in Ontario must have a minimum one year of Canadian experience under the supervision of a licensed professional engineer.

The OFC conducts annual reviews of the registration practices of all regulatory bodies in Ontario, including PEO.

In a March 15, 2018, letter to PEO—and in subsequent face-to-face meetings in April and July—Fairness Commissioner Grant Jameson stated that PEO’s mandatory Canadian experience fails to meet an Ontario Human Rights Commission policy requiring “regulatory bodies to show that a requirement for prior work experience in Canada is a bona fide requirement.” As a result, Jameson stated that PEO is not living up to its duties in the Fair Registration Practices Code of the Fair Access to Regulated Professions and Compulsory Trades Act.

In an August 2, 2018, letter to Jameson, PEO Interim Registrar Johnny ZucconP.Eng., FEC, responded to Jameson’s concern, noting that PEO has a mandate to protect public safety, and pointed out that:

  • To assure public safety, applicants must demonstrate their professionalism and competency under the supervision of an experienced licensed engineer, providing assurance that they meet PEO’s high standards;
  • All applicants, regardless of their country of origin or education, must meet the one-year Canadian work experience;
  • The Professional Engineers Act allows any adult to practise professional engineering so long as a licence holder assumes responsibility for their work;
  • A provisional licence was developed in 2003 to assist applicants who meet all licensing requirements except the Canadian experience to find Canadian engineering employment; and
  • All 12 Canadian engineering regulators have universal licensing requirements to ease inter-provincial mobility.

Jameson, who became fairness commissioner in 2017, noted that PEO’s rationale behind the one year of Canadian experience under the supervision of a licensed engineer—reaffirmed in a 2015 PEO Council statement—is “insufficient,” as “it focuses on the importance of an applicant receiving validation from an individual already licensed by PEO and does not demonstrate openness to alternative methods for applicants to prove they are fully competent to practise in Ontario.” Jameson also expressed disappointment that PEO’s involvement in an Engineers and Geoscientists British Columbia–led competency initiative has yet to produce an alternative.

The initiative is a competency model that Zuccon noted integrates eight competencies directly related to Canadian engineering into the licensing framework. These competencies can be partially demonstrated by 60 hours of online training and augmented by supervised experience. However, the project is ongoing, and Zuccon informed Jameson that “more work must be done before alternative assessment methods can be considered…PEO staff is currently researching alternatives, including a structured internship requirement and replacing the fixed, 12-month experience with a flexible one.”


The fairness commissioner also raised concerns regarding the review process of PEO’s Academic Requirements Committee (ARC); principally, Jameson expressed that internal reviews of applicants’ files should not be completed by the same assessor who completed the initial review. According to Acting Deputy Registrar, Licensing and Registration Moody Farag, P.Eng., PEO currently makes every effort to have each review conducted by a different assessor.

The fairness commissioner also requested that PEO’s Experience Review Committee (ERC) develop clear guidelines relating to situations of potential biases and conflicts of interest. Pauline Lebel, P.Eng., PEO’s manager of licensure, noted the ERC has long had an unwritten policy to deal with potential biases and conflicts of interest, but they have now been written and formalized.