BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:April 25, 2011        |Bill No:SB                         |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                          Senator Curren D. Price, Jr., Chair
                                       

                         Bill No:        SB 692Author:Walters
                   As Introduced:      February 18, 2011Fiscal: Yes

        
        SUBJECT:  Professional engineers.
        
        SUMMARY:  This is an Urgency measure.  In addition to civil, 
        electrical and mechanical engineering, further establishes 
        agricultural, chemical, control system, fire protection, industrial, 
        metallurgical, nuclear, petroleum, and traffic engineering as 
        "practice acts" under the Professional Engineers Act (as opposed to 
        "title acts") and generally incorporates these nine additional 
        practice act disciplines into the provisions relating to the three 
        existing practice acts.

        Existing law:
        
        1) Licenses and regulates professional engineers, land surveyors, 
           geologists and geophysicists by the Board for Professional 
           Engineers, Land Surveyors, and Geologists (Board) within the 
           Department of Consumer Affairs.

        2) Recognizes, under the Professional Engineers Act (Act), three 
           branches of engineering as "practice acts" (civil, mechanical, and 
           electrical), nine branches of engineering as "title acts" 
           (agricultural, chemical, control system, fire protection, 
           industrial, metallurgical, nuclear, petroleum, and traffic), and 
           two "title authorities" (structural and soil).  Any person 
           registered under a practice act may perform any engineering work 
           considered to be agricultural, chemical, control system, fire 
           protection, industrial, metallurgical, nuclear, petroleum, or 
           traffic engineering. (Business and Professions Code (BPC) 
           commencing with Section 6700)






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        3) Defines "responsible charge of work" to mean the independent 
           control and direction, by the use of initiative, skill, and 
           independent judgment, of the investigation or design of 
           professional engineering work or the direct engineering control of 
           such projects. (BPC � 6703)

        4) Requires that any person, unless specifically exempted, who 
           practices, or offers to practice, civil engineering, electrical 
           engineering or mechanical engineering must be accordingly licensed 
           by the Board. (BPC � 6730)

        5) Provides that it is a misdemeanor for any person not licensed by 
           the Board or exempted by law, to practice or offer to practice as a 
           civil, electrical or mechanical engineer.  Also provides that it is 
           a misdemeanor for any person to use the title of licensed or 
           registered civil, electrical, or mechanical engineer, or any other 
           title that implies the person is practicing within one of these 
           branches, unless the person is licensed by the Board. (BPC � 6787)

        6) Authorizes a civil engineer to practice, or offer to practice, any 
           engineering in connection with or supplementary to civil 
           engineering. (BPC � 6737.2)

        7) Required DCA to contract with an independent consultant to 
           determine whether or not certain title acts should be eliminated, 
           kept, or converted into practice acts, and to report the findings 
           and recommendations to the Legislature by September 1, 2002. (BPC � 
           6704.1)


        This bill:

        1) In addition to civil, electrical and mechanical engineering, 
           establishes agricultural, chemical, control system, fire 
           protection, industrial, metallurgical, nuclear, petroleum, and 
           traffic engineering as "practice acts" in California (as opposed to 
           "title acts") and generally incorporates these nine additional 
           practice act disciplines into the provisions relating to the three 
           existing practice acts.  The bill provides that only those 
           individuals licensed by the Board may practice in these branches of 
           engineering.

        2) Provides that it is a misdemeanor for any person not licensed by 
           the Board or exempted by law, to practice or offer to practice as 
           an agricultural, chemical, control system, fire protection, 
           industrial, metallurgical, nuclear, petroleum, or traffic engineer. 





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            Also provides that it is a misdemeanor for any person to use the 
           title of licensed or registered agricultural, chemical, control 
           system, fire protection, industrial, metallurgical, nuclear, 
           petroleum, or traffic engineer, or any other title that implies the 
           person is practicing within one of these branches, unless the 
           person is licensed by the Board.

        3) Defines the following branches of engineering in statute:  
           Agricultural, chemical, control system, fire protection, 
           industrial, metallurgical, nuclear, petroleum, and traffic; with 
           regard to the defined branches, provides:

           a)   The definitions shall not be construed as regulating any 
             generally recognized profession other than professional 
             engineering, even when the duties and practices of that 
             profession overlap those defined duties and practices.

           b)   All engineering plans, specifications, calculations, and 
             reports (documents) prepared by a licensed engineer shall bear 
             the signature or seal, and other specified information, of the 
             engineer.

           c)   A licensed engineer who signs engineering documents shall not 
             be responsible for any damage caused by subsequent changes to or 
             uses of the documents if those changes are not approved by the 
             licensed engineer who originally signed the documents.

        1) Provides that a professional engineer may practice engineering work 
           only in the field or fields in which he or she is by education or 
           experience competent and proficient, and additionally provides 
           that: 

            a)    Any engineer may practice without limitation in the branches 
              of agricultural engineering, chemical engineering, control 
              system engineering, fire protection engineering, industrial 
              engineering, metallurgical engineering, nuclear engineering, 
              petroleum engineering, and traffic engineering.

            b)    No local agency may impose limits on a licensed engineer's 
              ability to practice engineering before that agency.

        2) Defines "professional engineering services" as agricultural, 
           chemical, civil, control system, electrical, fire protection, 
           industrial, mechanical, metallurgical, nuclear, petroleum, or 
           traffic engineering services.






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        3) Provides that engineers in each practice discipline (agricultural, 
           chemical, civil, control system, electrical, fire protection, 
           industrial, mechanical, metallurgical, nuclear, petroleum, and 
           traffic engineers) may practice, or offer to practice, within the 
           scope of their license as a sole proprietorship, partnership, firm, 
           or corporation as long as specified conditions are met for 
           professional engineering services provided.

        4) Deletes an outdated provision requiring the DCA to contract with an 
           independent consultant to determine whether or not certain title 
           acts should be eliminated, kept, or converted into practice acts.

        5) Makes technical and conforming changes to incorporate the bill's 
           conversion of the nine title acts into practice acts.


        FISCAL EFFECT:  Unknown.  This bill has been keyed "fiscal" by 
        Legislative Counsel.


        COMMENTS:
        
        1. Purpose.  This bill is sponsored by  California Farm Bureau 
           Federation  (Sponsor) to revise the Professional Engineers Act to 
           regulate all engineering disciplines in the same manner.  It would 
           allow overlap between disciplines without arbitrary restrictions.  
           The regulation requiring engineers to be competent when providing 
           services is codified.  

        The Sponsor states: "Civil engineering is the only discipline that is 
           allowed to overlap into other disciplines.  California is the only 
           state that does not allow overlap in both directions.  No other 
           discipline is allowed to perform civil engineering."  

        The Sponsor further indicates:  "Civil engineering is focused on 
           protecting the integrity of structures from loads and dynamic 
           forces.  The definition of civil engineering states any design or 
           services provided for fixed works is civil engineering.  Public 
           safety involves issues far beyond structural integrity.  Growing 
           and processing food with safety for consumers, safe chemical 
           processes, fire protection for buildings, remedial actions to clean 
           contaminated sites to safe conditions, are all situations addressed 
           by disciplines that need the flexibility civil engineers have in 
           practicing their profession.  Competence is the main requirement 
           engineers must meet."






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        2. Background.  For nearly thirty years the Board has struggled with 
           practice and title act registration without resolving what the 
           appropriate level of regulation should be.  There are currently 
           three practice-restricted disciplines (civil, electrical and 
           mechanical), and nine engineering specialty "title acts" regulated 
           by the Board:  Agricultural, chemical, control systems, fire 
           protection, industrial, metallurgical, nuclear, petroleum and 
           traffic.  The title acts grant recognition to those engineers who 
           have met the experience and testing requirements of the Board, and 
           only allow those who have met the qualifications to call themselves 
           "professional engineers" and use the specific engineering title.  
           However, it does not restrict other engineers or non-engineers from 
           offering similar services in those engineering disciplines.

        California is unique in offering title act registration.  Other states 
           have "generic" licensing laws where all engineers are licensed 
           (registered) as professional engineers.  There are generally no 
           restrictions on the use of the specialty title, but just on the use 
           of the term "professional engineer."  However, an engineer who is 
           working in the area of industrial engineering, (for example, a 
           California title act branch) would have to be licensed with that 
           state, since any engineer practicing or offering to practice 
           engineering must be licensed unless some exemption applies.  In 
           many states the exemptions for licensure are somewhat narrow and 
           restrictive.

        3. Prior Legislation to Convert Title Acts to Practice Acts.  This 
           bill is essentially identical to  SB 275  (Walters) from the 
           2009-2010 Legislative Session.  That bill was sponsored by the 
           California Farm Bureau Federation along with the Chemical Industry 
           Council of California, and ultimately died in this Committee.

        This bill is also similar to  SB 246  (Figueroa) from 2005 (as amended 
           on June 20, 2005).  That bill was sponsored by the Board, and 
           incorporated a number of the recommendations of the Joint Committee 
           on Boards, Commissions and Consumer Protection (Joint Committee).  
           However there are some significant differences between SB 246 and 
           this bill, which are noted below.

        For a number of years, the Joint Committee had worked with the Board 
           and various stakeholders in conjunction with the Board's efforts to 
           rewrite the Professional Engineering Act.  In its recommendations 
           made in 2005, after reviewing information provided by the Board 
           regarding all title acts, including the number of current 
           licensees, number of licensees originally grandfathered, rates of 
           attrition, number of examinees tested over the years and the 





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           potential for continued licensure and testing in the particular 
           discipline of engineering, the Joint Committee determined that  the 
           title acts of agricultural, industrial and metallurgical 
           engineering should be allowed to phase out over time  , similar to 
           the title acts of corrosion, quality, safety and manufacturing.  
           Further, the Joint Committee recommended that the remaining title 
           acts, chemical, control systems, fire protection, nuclear, 
           petroleum and traffic engineering, be converted to practice acts.  
           Those recommendations were crafted into legislation which was 
           sponsored by the Board for Professional Engineers and Land 
           Surveyors and incorporated into SB 246.

        The recommendation to convert the title acts to practice acts was the 
           culmination of an extended process involving the Joint Committee, 
           the Board, a Board Task Force, and an independent study conducted 
           by the Institute of Social Research (ISR) at California State 
           University Sacramento.  The Joint Committee concluded that SB 246 
           was necessary because:  (1) the current regulatory system was 
           nonsensical and in need of reform; (2) the elevation of six title 
           acts to practice acts would better protect the public by ensuring 
           that only those who have the necessary education and experience may 
           practice as a chemical, control systems, fire protection, nuclear, 
           petroleum or traffic engineer; (3) the conversion of the six title 
           acts to practice acts would bring equity and fairness to the 
           profession.

           a.   Practice Act vs. Title Act.  The most contentious issue of SB 
             246, and of the current bill, is the elevation of title acts to 
             the level of practice acts.  Opponents argue that there is little 
             public benefit in converting the title acts into practice acts, 
             and that it would be confusing to the public, and foster greater 
             fractionalization of the engineering profession.  Proponents, 
             however, argue that the title branches are distinct engineering 
             disciplines and should not be regulated as subsets of the 
             existing practice acts.  Proponents believe that creating the new 
             practice acts would bring equality and equity to professional 
             engineering.

           b.   Institute of Social Research Report.   SB 2030  (Figueroa, 
             Chapter 1006, Statutes of 2000) required DCA to contract with an 
             independent consultant to conduct a study of California's 
             regulatory regime with respect to professional engineers.  
             Accordingly, the study was performed by the Institute of Social 
             Research (ISR) which, among other tasks, researched and examined 
             the regulation of professional engineers in California, the 
             education requirements of engineers, the testimony of 





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             stakeholders, and compared California's regulatory regime to that 
             of other states.  The ISR report was released in November of 
             2002, and made a number of recommendations to reform California's 
             regulation of professional engineers.

           Among these recommendations, ISR recommended the removal of "all 
             prohibitions against overlapping practice between engineering 
             disciplines from the Professional Engineers Act and Board Rules." 
              In addition, ISR found that no other state has a regulatory 
             structure for engineers like California's hierarchical regulatory 
             structure.  The report found that California's unique regulatory 
             structure was unjustified and recommended that the state 
             "eliminate title protection and offer practice protection to all 
             regulated disciplines."  Primarily, ISR made this recommendation 
             because by offering only title act protection to various branches 
             of engineering, the state permits any individual to practice 
             within those branches so long as he or she does not use one of 
             the protected titles such as "chemical engineer" or "nuclear 
             engineer."  ISR found that "no other state allows the unlicensed 
             practice of regulated engineering disciplines."  ISR also 
             reported that most other states offer a generic "professional 
             engineer" license (similar to the licensing of physicians and 
             surgeons, architects, and attorneys).

           c.   Review of ISR Report by the Board.  As indicated above, ISR 
             made several recommendations in November 2002, to the Board 
             regarding the continued licensure and regulation of engineers in 
             individual disciplines of engineering, the reporting of legal 
             actions against engineers, and the collection of information 
             regarding the practice of engineering in California.  It was 
             decided by the Board, DCA, and the Joint Committee to have this 
             ISR study reviewed by a Task Force appointed by the Board 
             consisting of two members of the Board, committee consultants of 
             the Legislature, a representative from DCA, and various other 
             members of the public and two engineers not affiliated with the 
             Board.  The Task Force began meeting in August of 2003, and held 
             five meetings throughout the state to discuss the ISR 
             recommendations and receive public comment regarding those 
             recommendations or others being considered by the Task Force.  In 
             2004, the Board approved the recommendations of the Task Force 
             which were then adopted by the Joint Committee.  SB 246, as 
             amended on June 20, 2005, reflected the changes to the Engineers 
             Licensing Act necessary to implement those recommendations.

           d.   Opposition to SB 246.  The bill was strongly opposed by two 
             professional associations representing a large segment of 





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             engineers in the state.  The Consulting Engineers and Land 
             Surveyors of California (now known as American Council of 
             Engineering Companies) and the Professional Engineers in 
             California Government argued that there would be no public 
             benefit from converting the title acts into practice acts, and 
             permitting any licensed engineer to practice in any other branch 
             of engineering would, in essence, allow engineers to 
             "self-certify" that they are qualified to practice in any other 
             branch.  Ultimately, the bill was held under submission in the 
             Assembly Business and Professions Committee, and eventually the 
             bill was amended to make it deal with another subject altogether.

        1. Differences in This Measure and SB 246.  As indicated above, SB 246 
           from 2005, would have converted six title acts (chemical, control 
           systems, fire protection, nuclear, petroleum and traffic 
           engineering) to practice acts, and removed the prohibitions against 
           overlapping practice between engineering disciplines in the 
           Professional Engineers Act, and instead allowed the title act 
           engineers to practice in areas in which the engineer was by 
           education or experience competent and proficient.  The bill would 
           also have given all regulated disciplines the right to responsible 
           charge of engineering projects when justified by their education 
           and experience.  That bill further would have allowed the title 
           acts of agricultural, industrial and metallurgical engineering to 
           phase out over time as had been done to the title acts for 
           corrosion, quality, safety and manufacturing due to the apparent 
           paucity of registrants.

        The current bill before the Committee, SB 692, makes essentially the 
           same changes; however, the significant differences are:  (1) this 
           bill converts  all   nine  title acts into practice acts; (2) this bill 
           does not authorize the newly created practice acts to overlap into 
           civil, electrical and mechanical engineering.

        2. Practice Act Descriptions.  As drafted, the bill converts the nine 
           title acts into practice acts by codifying the title descriptions 
           essentially as they are currently found described in the 
           regulations adopted by the Board.  Specifically, under current law, 
           the title acts are contained in, California Code of Regulations 
           (CCR), Title 16, Division 5, Section 404.  In order to establish 
           the scope of practice based on the descriptions, the bill further 
           adds to each definition that a person practices that branch of 
           engineering when he or she professes to practice or is in 
           responsible charge of engineering work in that branch.

        3. Restrictions on Title Act Engineers Design Authority.  Throughout 





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           state government, because title act engineers are not considered 
           engaged in an engineering "practice" they are not permitted to be 
           in "responsible charge" of a project.  The California Fire Chief's 
           Association gives several such examples:
        
                Office of Statewide Health Planning and Development (OSHPD)  - 
             Because fire protection engineering is not considered a 
             "practice" OSHPD holds that fire protection engineers do not fall 
             within the exception of Health and Safety Code (HSC) � 129805, 
             permitting them to design fire protection and life safety systems 
             in hospitals and skilled nursing facilities.

                Division of State Architect (DSA)  - Because fire protection is 
             not considered an approved practice for performance of any 
             education facility related services, a fire protection engineer 
             cannot perform design or construction related services on school 
             projects (Education Code � 17302).

                Local Government; High Rise Buildings  - Some local agencies do 
             not consider fire protection and engineering, "practice," and 
             therefore cannot be in responsible charge of a fire protection or 
             life safety project and cannot perform design services or oversee 
             construction of a fire alarm and fire protection systems in high 
             rise structures.  California Building Code � 1.11.3.3(2) 
             provides, "All plans and specifications shall be prepared under 
             the responsible charge of an architect or a civil or structural 
             engineer authorized by law to develop construction plans and 
             specifications."
         
        1. Licensing Populations.  It may be helpful to the Committee to 
           understand the numbers of engineers registered in each branch of 
           engineering in the state.  The chart below shows the number 
           registered in the current three practice acts and nine title acts 
           that are covered by this bill.  The statistics are taken from the 
           Board's 2010 Sunset Review Report, the most recent available.  The 
           licensing numbers show that the vast majority of engineers are 
           licensed in the three practice acts:  civil, electrical and 
            mechanical.  A lesser number are licensed in the nine title acts:  
           agricultural, chemical, control system, fire protection, 
           industrial, metallurgical, nuclear and traffic.
        
        
             ------------------------------------------------------ 
            |  2010 Sunset Review Report.  FY 2009-2010 Licensing  |
            |                      Statistics                      |
             ------------------------------------------------------ 





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            |---------------+---------+----------+----------------|
            |     Type      | Issued  | Renewed  |  Total Active  |
            |               |         |          |    Licenses    |
            |---------------+---------+----------+----------------|
            |Agricultural   |        0|        79|             193|
            |---------------+---------+----------+----------------|
            |Civil          |    1,867|    27,120|          50,497|
            |---------------+---------+----------+----------------|
            |Chemical       |       71|     1,032|           1,954|
            |---------------+---------+----------+----------------|
            |Control System |      11 |       499|           1,416|
            |---------------+---------+----------+----------------|
            |Electrical     |      398|     3,812|           8,916|
            |---------------+---------+----------+----------------|
            |Fire           |       29|       367|            760 |
            |Protection     |         |          |                |
            |---------------+---------+----------+----------------|
            |Industrial     |        5|       116|             467|
            |---------------+---------+----------+----------------|
            |Mechanical     |      478|     7,395|          14,633|
            |---------------+---------+----------+----------------|
            |Metallurgical  |        6|       174|             277|
            |---------------+---------+----------+----------------|
            |Nuclear        |        2|       392|             613|
            |---------------+---------+----------+----------------|
            |Petroleum      |        4|       207|             389|
            |---------------+---------+----------+----------------|
            |Traffic        |       33|       733|512             |
            |               |         |          |                |
             ----------------------------------------------------- 

        2. Related Legislation.   SB 543  (Price) extends the inoperative and 
           repeal dates (sunset dates) for the Board as well as for several 
           other regulatory boards from January 1, 2012 to January 1, 2016, 
           and makes several updates to the regulatory law.  At the request of 
           the Committee those boards and bureaus with a January 1, 2012 
           sunset date, submitted their Sunset Report to the Legislature in 
           the Fall of 2010.  In March of this year, the Committee held 
           oversight hearings to review those boards that needed legislation 
           to extend their sunset dates in 2011.  Recommendations from those 
           oversight hearings which needed legislative changes were amended 
           into several pieces of legislation which also extend sunset dates 
           for the various boards and bureaus.  The sunset extension bills, 
           each Authored by Senator Price, are:  SB 538, SB 539, SB 540, SB 
           541, SB 542, and SB 543.  These bills will be heard in this 
           Committee on May 2, 2011.





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        AB 1210  (Garrick) requires all civil engineering activities performed 
           in the preparation, submission, execution, and enforcement of 
           stormwater pollution prevention plans pursuant to a permit for 
           stormwater discharges from the State Water Resources Control Board 
           to be prepared and performed under the responsible charge of a 
           licensed civil engineer.  This bill is awaiting hearing in the 
           Assembly Business, Professions and Consumer Protection Committee. 

            ABX4 20  (Strickland, Chapter 18, Statutes of 2009) made a number of 
           consolidations related to the 2009-2010 State Budget, including 
           consolidating the Board of Geologists and Geophysicists with the 
           Board for Professional Engineers and Land Surveyors.

            AB 1431  (Hill, Chapter 696, Statutes of 2010) renamed the Board for 
           Professional Engineers and Land Surveyors, to become the Board for 
           Professional Engineers, Land Surveyors and Geologists, and 
           increased the Board membership from 13 to 15 by adding a licensed 
           geologist or geophysicist to the Board, and one public member.

        3. Arguments in Support.  In sponsoring the bill, the  California Farm 
           Bureau  (Sponsor) states that California is responding to new 
           requirements for food safety, to reduce impacts on the environment, 
           and to reduce green house gas emissions and the engineering 
           profession part of this effort.  The present law restricts any 
           engineer, who is not licensed as a civil engineer, from helping 
           farmers to meet the new challenges.  Yet there are experts with the 
           ability to do this who are not civil engineers.  The Sponsor 
           further argues:  "Any engineering for fixed work is prohibited 
           unless it is performed by a licensed civil engineer.  While it is 
           important to make sure buildings withstand earthquakes, it is also 
           important to reduce pesticide and herbicide discharges, provide 
           clean food processing facilities, and make efficient use of 
           irrigation water.  Agricultural and chemical engineers are usually 
           the most expert in these areas."

        The  California Legislative Council of Professional Engineers  (CLCPE) 
           argues that because of the current law, state agencies restrict the 
           ability of title protected engineers to provide the designs, and 
           other engineering services, best suited to protect the public.  At 
           best, this causes extra costs and delays projects.  The best 
           engineering technology is provided when the law is ignored, and 
           competence is allowed, according to CLCPE.

        CSCPE states:  "The time has come to bring California into the 21st 





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           Century by providing all licensed engineers equal respect.  Other 
           states encourage all engineers to use their expertise to protect 
           the public and the environment.  California discourages such 
           activity, since it is more important to look to status, instead of 
           competence, in our state.  CLCPE  indicates that California is 
           leading the world in a technical revolution to address 
           environmental and energy issues, and needs bold steps to be taken 
           toward technologies that are just on the drawing board, affirming, 
           "This is a difficult task, at best.  Without reforming the 
           Engineering Act, the difficulties may be insurmountable."

        A number of individual engineers have written, stating that they are 
           employees of California environmental regulatory agencies (many of 
           whom are members of the Professional Engineers in California 
           Government), and are in support of the bill.  These engineers 
           indicate they are employed by various agencies, including:  
           Department of Toxics Substances Control (DTSC), State Water 
           Resources Control Board (SWRCB), California Department of Public 
           Health (CDPH), CDPH Drinking Water Program (CDPH-DWP), Division of 
           Drinking Water and Environmental Management (DDWEM), Regional Water 
           Quality Control Board, Air Resources Board, Bay Area Air Quality 
           Management District.  These supporters argue that the current 
           definition of civil engineering is so broad that, everything they 
           do is included in the definition, stating, "It only allows civil 
           engineers to perform many of the services for which we have the 
           formal education or experience to conduct."  Further stating, "We 
           find the scope of civil engineering is so broad it prohibits the 
           provision of services from engineers who are not licensed as civil 
           engineers, merely because they are not licensed as civil engineers. 
            It appears that in the State's eyes, the requirement that the work 
           be conducted by a civil engineer is more of a concern than the 
           competence of the service provided."

        The  California Fire Chiefs Association  states that the fire prevention 
           and code enforcement divisions rely on the services of Title Act 
           engineers, particularly fire protection engineers, and chemical 
           engineers in performing public safety services.  These engineers 
           provide specialty expertise, to address the unique problems in 
           current fire protection and hazardous materials technology.

        4. Arguments in Opposition.  The  American Council of Engineering 
           Companies of California  (ACEC), opposes the bill, arguing that the 
           practice acts created by SB 692 would overlap with one another and 
           with existing practice acts, confuse consumers, force the use on 
           projects of more engineers with different types of licenses, add to 
           consumer costs and make California's licensing laws even more 





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           disconnected than they already are with the licensing laws in other 
           states (which would make it more difficult for California's 
           engineers to provide services for projects located in other 
           states).  ACEC contends that the law prohibits civil, electrical, 
           and mechanical engineering by any person who has not passed a 
           specified examination and who is not appropriately licensed by the 
           board in that discipline, and that eliminating specific title acts 
           and elevating all engineering work to practice acts "undermines 
           this critical safety and education component, and allows people 
           with no prior education or examination determination to practice in 
           the areas of civil, electrical, and mechanical engineering."

        According to ACEC, the bill would further fragment the profession and 
           make project delivery more cumbersome and costly at a time when 
           California is already failing to graduate enough engineers needed 
           for future growth and prosperity, and when infrastructure and 
           housing needs are immense and growing.

         Professional Engineers in California Government  (PECG), also opposes 
           the bill, stating, "When this measure was first introduced (SB 246, 
           2005), PECG provided written recommendations to the Senate 
           Business, Professions and Economic Development Committee in April 
           of 2004, as well as April of 2005, outlining the public policy 
           reasons that support their steadfast opposition to proposals to 
           convert engineering Title Acts to Practice Acts.  In short, the 
           purpose of Practice Act licensing is "to safeguard life, health, 
           property and public welfare" (Business and Professions Code Section 
           6730).  Currently, the practice licenses are civil engineering, 
           electrical engineering and mechanical engineering.  Practice Act 
           licenses, by definition, should only be created if they are needed 
           for statutory purposes.  PECG also opposed SB 275, an identical 
           bill from last session.  PECG does not believe that converting 
           Title Act registrants, as proposed in SB 692, is necessary to 
           safeguard life, health, property and public welfare."

        5. The Board Has No Position on This Bill.  Although the Board for 
           Professional Engineers and Land Surveyors sponsored SB 246 in 2005, 
           it did not take a position on SB 275 in the 2009-2010 Session, nor 
           has it taken a position on the current measure.

         6. Policy Issue  :  Should the specified Title Acts be converted to 
           Practice Acts?  After lengthy review of this issue for many years, 
           there does not seem to be any real justification for continuing 
           with title acts for those disciplines of agricultural, chemical, 
           control system, fire protection, industrial, metallurgical, 
           nuclear, petroleum and traffic engineering.  Currently, all of the 





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           title act engineers are considered as "licensed" by the Board, yet 
           because of their status as a title engineer the only real action 
           the Board may take against them for incompetent practice is to no 
           longer allow them to use their title.  From a consumer protection 
           standpoint, this serves no purpose in trying to prevent future 
           practice of incompetent title act engineers.  Consumers are also 
           misled by the use of the term "licensed" since a licensed 
           professional is considered as having specified practice 
           restrictions or what is considered as a defined scope of practice.  
           Practice act versus title act engineers has for years created two 
           classes of engineers, those who have a legitimate practice and 
           those who have something less.  No other states classify engineers 
           in this fashion.  What it has allowed is for the three practice 
           areas of engineering (civil, electrical and mechanical) to govern 
           the engineering work of title act engineers even though they may 
           have little experience in these specialty areas of engineering.  As 
           previously pointed out, the conversion of title acts to practice 
           acts is an issue of equity and fairness to the entire profession of 
           engineering.

         7. Policy Issue  :  Should there be a uniform standard of practice and 
           competency for all licensed engineers?  This measure provides that 
           a professional engineer may practice engineering work only in the 
           field or fields in which he or she is by education or experience 
           competent and proficient.  Currently this competency requirement in 
           Board regulations only applies to civil, electrical and mechanical 
           engineering and only as to the engineering services they may 
           provide within their own particular practice.   Under this bill, 
           this standard of competency would apply to all disciplines of 
           engineering and would insure that any engineering work performed 
           within a particular practice of engineering, or in another area of 
           engineering (including the former title act disciplines), could 
           only be done if the engineer is by education or experience both 
           competent and proficient to perform the engineering services.  This 
           provides greater consumer protection, since the Board would be able 
           to take action against any licensed engineer who performs 
           incompetent work in their own discipline of engineering, or in 
           other disciplines of engineering, because they do not have the 
           requisite education or experience to be performing such engineering 
           work.

         8. Policy Issue  :  Should a professional engineer be allowed to be in 
           responsible charge of work in the branch in which he or she is 
           educated, trained and licensed?  BPC Section 6703 defines 
           "responsible charge of work" as the independent control and 
           direction, by the use of initiative, skill, and independent 





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           judgment, of the investigation or design of professional 
           engineering work or the direct engineering control of such 
           projects.  Board regulation (CCR � 404.1) provides that responsible 
           charge directly relates to the extent of control a professional 
           engineer is required to maintain while exercising independent 
           control and direction of professional engineering services or 
           creative work and to the engineering decisions which can be made 
           only by a professional engineer.   

        In determining the criteria for whether an engineer is in responsible 
           charge, CCR � 404.1 further states that certain elements must be 
           considered, and includes:  "The professional engineer who signs 
           engineering documents must be capable of answering questions asked 
           by individuals who are licensed by the Board in the appropriate 
           branch of professional engineering relevant to the project and who 
           are fully competent and proficient by education and experience in 
           the field or fields of professional engineering relevant to the 
           project."  

           Proponents of this bill argue that a basic problem in professional 
           engineering practice, and a key reason why this bill is needed, is 
           that title act engineers are not currently permitted to be in 
           responsible charge of engineering projects in which they are 
           educated, experienced and proficient; and, instead, a civil 
           engineer must be in the position of responsible charge for 
           engineering projects within the title act engineer's field.  
           According to the proponents, this puts the civil engineer in the 
           position of signing off on work which he or she may have very 
           little knowledge about, which the engineer who is an expert in that 
           field is unable to sign off on his or her own work. 
        

        SUPPORT AND OPPOSITION:
        
         Support:   

        California Farm Bureau Federation (Sponsor)
        California Legislative Council of Professional Engineers (CLCPE)
        California Fire Chiefs Association
        Numerous individuals 

         Opposition:   

        American Council of Engineering Companies
        Professional Engineers in California Government






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        Consultant:G. V. Ayers