october 2009 issue
|
|
Professional Practice & Ethics Corner
APEGGA members with professional practice or ethics questions are welcome to mail them to Ray Chopiuk, P.Eng., Director, Professional Practice, APEGGA, 1500 Scotia One, 10060 Jasper AVE NW, Edmonton, AB T5J 4A2; fax them to 780-426-1877; or e-mail them to rchopiuk@apega.ca. |
 |
Q I work for a provincial agency reviewing reports written by environmental consulting firms. My job is to assess the technical validity and completeness (as compared to published provincial guidelines) of these reports, and provide a written statement (memo) with my findings and recommendations for future actions. I sign these with my APEGGA stamp.
A colleague has indicated that I cannot use the stamp, because I have not reviewed all the material the consultant had available to write the report, and thus I have no idea whether what is reported is correctly based on all the information the consultant had.
I argue that my job is only to assess the consultant report (and whatever information is provided with the report), and thus my findings memo reflects my best professional opinion. I am not responsible for the information used to write the consultant’s report that was not included with it. However, I can mention that if some conclusions are made without supporting information, that this information be submitted.
Thus I can, and should, sign the report with my APEGGA stamp, since I am performing my duties as a registered APEGGA professional.
Please let me know if I should stop using my stamp, and if so, why. Otherwise, I would appreciate you giving me further justification for using my stamp so I can settle the argument with my colleague.
A Stamping or not stamping your memo is not the most important aspect of what you are doing. Your signature at the bottom of the memo would already link you to the statements contained in it. Stamping will not change the effect of what you say in your assessment.
If the agency’s assessment of the consultant’s report requires engineering or geoscience judgment, then the assessment can only be done by someone who is registered as an engineer or geoscientist. Your stamp assures the reader of your assessment that you are registered as an engineer or geoscientist with APEGGA and are, therefore, entitled to conduct that assessment.
Typically, the agency would know which of its employees are engineers and geoscientists and which are not; stamps wouldn’t be necessary to communicate that. However, the regulations under the Engineering, Geological and Geophysical Professions Act concerning stamping do not differentiate between internal documents and those going externally. Furthermore, APEGGA’s Council recently confirmed that all documents of a professional nature must be stamped, including internal ones.
If the assessment only required someone to determine whether the consultant’s report was complete (i.e., simply that all the pieces were there), presumably that would not require a review by an engineer or geoscientist. No engineering or geoscience judgment would be involved and no stamp would be required.
You mentioned that you assess the “technical validity” of the reports. It’s not clear what that means, but if it means that you are checking and verifying the professional work of the consultant, someone might consider your actions as acceptance of professional responsibility for the consultant’s work. However, the consultant would have already taken professional responsibility for the contents of the report by (presumably) having stamped it. I don’t expect that’s what you intended, but the statements in your memo should be clear regarding the scope and limitations of the assessment.
My initial reaction to your question was that you wouldn’t need to stamp your assessment reports. However, from what you’ve said and after looking more closely at the wording in the EGGP Act, its regulations and APEGGA’s Practice Standard for Authenticating Professional Documents, I’ve concluded otherwise. In short, if your assessment expresses engineering or geoscience judgment (i.e., constitutes professional work), stamping the assessment report appears, indeed, to be a requirement.