Engineering Regulation UK vs USA Model

[SemiPE]

Hi All, I lived and studied in a country which follows the USA in terms of regulating the practice of engineering (Civil), that is PE license is given by a government authority which requires you to gain an x amount of experience then sit and pass the PE exam (plus an interview, in some instances).

However, I have been traveling and working in other countries that has a regulatory frame work similar to those of the UK. That is, submission of experience and qualification would suffice (plus an interview if required) to gain registration. Also, there are things called "Chartered Engineer" Status, which is a recognition of your professionalism, however this is not mandatory (more to do with selling your self) but this things are regulated by private organizations such as Istructe

Now, my question is why the USA & UK have a very big difference in the regulation of engineering (more particularly civil/structural)? Which one would be a better system in terms of regulating the profession?

 

[GregLocock]

I think the Germans and Canadians probably do it better than either of your options.

Cheers

Greg Locock


New here? Try reading these, they might help FAQ731-376

http://eng-tips.com/market.cfm?

 

[Debaser]

That's not quite right. Something called the Engineering Council is in overall charge of the basic standards one is required to meet to be classed as an Engineering Technician, Incorporated Engineer or Chartered Engineer.

https://www.engc.org.uk/

The likes of IStructE, ICE, CIHT, etc. are the various industry specific bodies through which you can gain professional registration.

https://www.engc.org.uk/professional-registration/

https://www.engc.org.uk/about-us/our-partners/professional-engineering-institutions/

 

[JStephen]

A couple of other issues I'll point out. One, the US system is state-by-state, not national, so there's not a "USA" system of regulating engineering, there are 50+ state and territory systems.
A lot of the engineering systems are based on the assumption that all engineers do the same thing, and if you don't fit into that system, it doesn't work as well. In my case, in order to show I was qualified to design tanks, I had to take a test about sizing pumps. Makes no sense. So the testing sounds good on paper, not quite as great in practice.
But, when I first got my license, in 1990, my state didn't require the tests, so I didn't take them. Then several years later, to get licensed in a different state, I had to take them.
States have also varied in the degree to which they will accept experience in lieu of education.
Perhaps worth pointing out that the educational systems of the different countries vary also.
I don't know how the UK works their engineering regulation. I know when I was in college, I would read the UK mechanical engineering magazine. I got the impression that mechanical engineering there overlapped the "being a mechanic" field a good bit, so I'm not sure what distinctions they had between the two. Anyway, the definition of "engineering" seemed to be somewhat different there.

 

[Teguci]

I'd like to establish for this comparison, the bones of what a PE is here in the States -

In the US, Licensing is typically as follows (with exceptions):
- Obtain an engineering degree at an accredited university
- Pass an 8 hour Engineer-in-Training Exam given by a national private testing organization (NCEES)
- Acquire 3 to 5 years (state dependent) of specified engineering experience that is attested to by previously licensed engineers
- Pass another 8 hour exam to receive the title Professional Engineer for the State you applied. If you want a license for another state, you have the above documented and submitted plus maybe another short test that is state specific (or not).

Licensing, to my knowledge, is mostly limited to and required in construction. Outside of construction it is not required and tends to be seen as an unnecessary liability risk.

Read through the UK Spec and still having a hard time understanding what is actually required. For instance, if a company wants to hook you up with all of the right experience and job exposure, it seems like you could be a chartered engineer within a year out of college? What am I missing? What becomes available at the different levels?

 

[tempeng]

I believe Incorporated (IEng) and Chartered (CEng) are the nearest equivalents to the PE status (but not quite). The usual route for the ICE (Civils) is degree/masters, project portfolio, evidence of professional development - seminars and the like, time on site and an interview. There is what called the Technical Report Route where you can present all of your experience in place of qualifications but you'll be expected to have kept track of 20 yrs of work experience and it can take a lot longer to achieve the status you're going for. It can take anywhere from ~3-5 yrs and onwards, depending on scope of your portfolio, with masters. For the structural engineers (IStructE) it's all of the above plus a seven hour exam covering various areas. There is a mutual acceptance scheme in place but you still need the relevant experience to qualify for whichever institution you're going for. All of this needs to overseen by someone whom is already incorporated or chartered with the institute of choice.

We also have the P.Eng from the Society of Professional Engineers but that isn't recognised by the engineering council; fine if you'd like to work in Europe for the most part though.

Non of this is a legal requirement to be a practising engineer. Membership of the institutions is completely optional although a lot of the bigger companies will insist on it. It only becomes a legal issue if you're claiming to be incorporated or chartered or even engineering technician level, and you're not or if someone is making claims to qualifications they don't hold.

If you want to know if you're status or even qualifications are acceptable, you really need to check with that country's governing body(ies). Equivalence is a bit of a dark hole.

 

[SemiPE]

Sorry if I wrote a blanket statement regarding the USA's licensing system, it is correct that its regulated depending on each states regulation.

I do agree with the statements put up by Teguci & Tempeng. Regulation in the USA is more straightforward compared in the UK (or should I say Europe in general) where there are alot of "titles" that can be assessed for that isn't necessarily required if an Engineer will signing off drawings (More specifically for civil/structural). Please do correct me if I'm wrong on this.

In short, the USA have a more rigorous exam based system, while the UK have a more reporting/documentation based system. But why the stark contrast? Appreciate a reply from someone practicing in the EU.

 

[tbuelna]

The US PE exams administered by NCEES are broken down into numerous engineering disciplines:

http://ncees.org/exams/pe-exam/

 

[tempeng]

It probably just comes down to the USA being state regulated whereas the UK and Europe are self governing, with each institute having their own set of by-laws and codes of conduct.

 

[SemiPE]

You are probably right tempeng. I feel that the USA is regulating the practice of engineering (civil/structural) in a similar way that they regulate the practice of law or medicine. On the other hand, the UK/Europe sees the practice of engineering in a different light than the practice of law or med.

 

[tempeng]

You are probably right tempeng. I feel that the USA is regulating the practice of engineering (civil/structural) in a similar way that they regulate the practice of law or medicine. On the other hand, the UK/Europe sees the practice of engineering in a different light than the practice of law or med.

I think it would take something catastrophic to happen (in the UK at least) before the government or local authorities would start regularising engineering practise. Like some sort of country wide gross incompetency issue.

 

[Ussuri]

In the UK, anyone can be an Engineer, anyone can call themselves an Engineer. There are no restrictions. This has been a bone of contention within the engineering community for many years, and is partly blamed for the lack of public recognition the UK has for Professional Engineers.

I think the UK approach relies very much upon honesty, especially in relation to technical ability. You have to demonstrate you meet the Engineering Council requirement but no one will check your design work line by line. The verification is done through mentoring during your career and through reports and interviews at the final review. This approach allows Engineers whose experience is not design related to get Chartered also, but will seem weak to those who believe it must be a technical challenge.

The US method of sitting exams seems more akin to your university experience. I think the downside is that this tests knowledge in a very narrow manner. We used to review past papers to question spot. It gave you a good chance of passing but you only learnt what you needed to pass.

The UK IStructE uses an exam. If you have experience which is an exact fit to the question then you have a good chance of passing, if not, then you are stuffed. That doesn't make you a bad engineer, it just means you can't pass the test.

 

[Teguci]

This seems like a concise and appropriate read from the US point of view.

https://en.wikipedia.org/wiki/Regulation_and_licensure_in_engineering

Noting the "In general there is no restriction on the right to practice as an engineer in the UK" clause, does this mean that anyone can put a building design together and have it built? How do the UK jurisdictions safeguard the public welfare when it comes to construction?

 

[Ussuri]

does this mean that anyone can put a building design together and have it built? How do the UK jurisdictions safeguard the public welfare when it comes to construction?

I suppose you can get people who break the law and please themselves, but that would be no different in the US. In general that responsibility falls to Building Control. Who are a function of local government (local councils). Before you erect a building you must apply to Building Control for a Building Warrant. Building Control then check that your design meets the requirements of the Building Regulations in respect of strength, fire, service etc etc. The requirements are freely available in the Building Regulations. This can be time consuming because BC need to check the calculations.

In Scotland they have a slightly different approach. Engineers register with Structural Engineers Registration (SER), during which process they are vetted. If they pass then they will be allowed to 'Self Certify', provided they can prove to Building Control that the design has been checked by someone competent. It is supposed to make the process quicker.

 

[Teguci]

At Ussuri:
In the UK, who takes responsibility for the design of a building that has received a "Full Plans" approval from the Building Control? If something is wrong with the approved design, do public servants get fined, fired or even go to jail?

 

[Ussuri]

I have never heard of anyone from the Council being held responsible. Responsibility will lie with the company (or individual). That would involve their PI insurance or if a criminal act has taken place then the relevant legal statutes would apply, for example Health and Safety Act or Corporate Manslaughter Act.

This discussion appears to be veering off the OP's original query.

 

[HoboMoe]

I can say about Russia, where I live. As in Germany we don’t have any license system for engineers. When you complete an engineering education you get a degree of Diploma engineer. That is absolutely enough for working. I think strict license system is mainly American practice.
Employer assesses you generally by job interview, tests and your portfolio. If you do something wrong you simply will be fired or in case something breaks even appear before a tribunal (but of course it happens very very rare, I even hardly can remember any cases). Generally top managers of project company bear all responsibility for possible damage (because they haven't find competent engineer for their task). But of course it doesn't mean that engineers lie down on their job. Because if client wants he will sue you as well.

 

[Teguci]

This discussion appears to be veering off the OP's original query.

The OP asked - "why the USA & UK have a very big difference in the regulation of engineering (more particularly civil/structural)? Which one would be a better system in terms of regulating the profession?"

To me, this liability issue is at the heart of the difference. In the US, we as professional engineers, legally take personal liability for designs when we stamp and seal the drawings. If there is something deficient with the design that causes harm to the public, it is on us. We, as individuals, have the full authority and responsibility for the design. If we sign and seal a drawing that includes other peoples' work, we not only take personal liability for that work but also are being legally unethical if that work was not performed under our direction and within our expertise. Unethical conduct by a PE is subject to personal fines, license revocation and reprimands.

As I understand it, in the UK, the company holds the authority and responsibility for the design. There is no named individual on the drawing (?)

As for which one is better, (assuming my interpretation is correct), I'm leaning towards the UK model. But I'd like to know more.

 

[tempeng]

As I understand it, in the UK, the company holds the authority and responsibility for the design. There is no named individual on the drawing (?)

Not quite. The designer and the checker both have to sign and date the drawings and calcs. The checking engineer is usually of chartered status and takes overall responsibility for the design team. The technical director also has a look over and adds his/her signature to the stack, which gets it covered by company insurance. So although it's the company that pays out via insurance, you can bet your dangley bits that it'll be the principle engineer that cops it should the excrement hit the bladed air circulator should it be proven that there's a design fault.

It can appear at first glance that personal responsibility isn't an issue but nothing ever works that way.

 

[tony1851]

To add my two-cent's worth; in the UK, anyone can work as a structural engineer without formal qualifications. That's been my own case (self-taught), though I trained as an architect (that word is protected). But I would never be employed by large companies as they would want to see paperwork. However, the work I do mainly involves small steel portals, plus work on domestic projects. The plans and details of any building work are checked by the local building control inspectors who retain their own checking engineers (building control may be by private firms or public authority at the clien's choice).