With the recent revisions to the SPCC plan regulations (see our August, 2002 newsletter), there has been a lot of discussion concerning the best way to review and update existing plans. Some people have asked if they can prepare the plan, and have us just provide the PE certification. The following information is from guidance to Professional Engineers concerning SPCC certification:
“One of the more frequent infractions of Engineering rules and regulations is the affixing of one’s seal to work not done under one’s direct supervision or responsible charge. The long-standing standard practice of the 50 states and 4 jurisdictions within the National Council of Engineering Examiners (NCEE) is not to permit the certification of work not performed by the licensee. In recent disciplinary matters, the Board has observed a greater incidence of the inappropriate use of the registrant’s seal . . . . The most frequent violation involves the registrant being provided documents for review and sealing when the registrant has provided no professional input in that particular work product. Board rules do not permit a registrant to review another’s work for adequacy or code compliance and then affix the Professional Engineer certification.
[Licensee] Question: Can I review engineering plans and specifications which were prepared by someone not registered as a Professional Engineer, and prepare a letter specifying the results of my review?
[Board] Answer: The Statutes prohibit the use of the registrant’s seal for the purpose of aiding and abetting any other person to evade or attempt to evade the provisions of this chapter.”
The general guidance is that the person doing the work has to be either the PE, or someone working for the PE and under the PE’s “direct supervision or responsible charge”. RCP is a registered professional engineering corporation, and we have several PEs on staff who are registered in multiple states. We would be glad to work with you to update and revise your existing SPCC plans. But our representative must visit the site, verify the data, and prepare the revisions to the plan in order for us to certify it.