A medical analogy
All industries require multiple roles to work together to achieve their mission. For instance, in a hospital, three of these roles are:
- Doctor
- Registered nurse; and
- Enrolled nurse.
Imagine what would happen if a law was passed that requires:
- Registered nurses to only perform enrolled nurses’ work, unless directly supervised by a doctor
- Doctors to perform registered nurses’ work, in addition to their existing work.
This is what the Victorian Professional Engineers Registration Act 2019 (the Act) is doing to the engineering profession – it requires:
- Engineering technologists to only perform engineering associates’ work, unless directly supervised by a professional engineer
- Professional engineers to perform engineering technologists’ work, in addition to their existing work.
There are three occupational categories within the engineering profession
The International Engineering Alliance defines three categories of engineering problems and activities:
- Complex
- Broadly-defined; and
- Well-defined.
The International Engineering Alliance has created three accords for the graduate attributes and professional competencies required for work with the three categories of engineering problems and activities (respectively):
- Washington
- Sydney; and
- Dublin.
Engineers Australia, as the principal engineering professional body within Australia, recognises these as occupational categories (respectively):
- Professional engineer
- Engineering technologist; and
- Engineering associate.
In Australia, the graduate attributes are typically achieved by (respectively):
- 4-year engineering qualification
- Australian Qualifications Framework level 8
- Bachelor Honours Degree
- 3-year engineering qualification
- Australian Qualifications Framework level 7
- Bachelor Degree
- 2-year engineering qualification
- Australian Qualifications Framework level 6
- Advanced Diploma or Associate Degree.
Engineers Australia assesses the professional competencies leading to registration or chartership (respectively):
- National Engineering Register (Professional Engineer) or Chartered Professional Engineer (CPEng)
- National Engineering Register (Engineering Technologist) or Chartered Technologist (CEngT); and
- National Engineering Register (Engineering Associate) or Chartered Associate (CEngA).
Engineers Australia membership is also aligned with the occupational categories (respectively):
- Member (MIEAust)
- Technologist Member (TMIEAust); and
- Associate Member (AMIEAust).
The Institution of Railway Signal Engineers, as the principal railway control systems engineering professional body, also aligns its registration with these occupational categories (respectively):
- Chartered Engineer (CEng)
- Incorporated Engineer (IEng); and
- Engineering Technician (EngTech).
This is summarised in the table below.
| Occupational category | Professional engineer | Engineering technologist | Engineering associate |
| Accord | Washington | Sydney | Dublin |
| Works with… | complex engineering problems | broadly-defined engineering problems | well-defined engineering problems |
| Graduate attributes typically achieved by… | 4-year Bachelor Honours Degree (AQF 8) | 3-year Bachelor Degree (AQF 7) | 2-year Advanced Diploma or Associate Degree (AQF 6) |
| Professional competency assessed by… | NER (Professional Engineer), CPEng | NER (Engineering Technologist), CEngT | NER (Engineering Associate), CEngA |
| Engineers Australia membership | Member (MIEAust) | Technologist Member (TMIEAust) | Associate Member (AMIEAust) |
| IRSE registration | Chartered Engineer (CEng) | Incorporated Engineer (IEng) | Engineering Technician (EngTech) |
In summary, there are three occupational categories within the engineering profession.
How could the occupational categories be distinguished in legislation?
The International Engineering Alliance gives seven attributes of engineering problems and five attributes of engineering activities for each occupational category.
Specifying all of these attributes in legislation (or even in associated guidelines) would be unwieldy.
A legally testable way of determining whether an engineering problem or activity is broadly-defined or well-defined is needed.
Engineering problems and activities can be defined in standards.
The International Engineering Alliance defines the extent of applicable standards as shown in the table below:
| Complex engineering problems | Address problems not encompassed by standards and codes of practice for professional engineering |
| Broadly-defined engineering problems | Address problems that may be partially outside those encompassed by standards or codes of practice |
| Well-defined engineering problems | Addresses problems that are encompassed by standards and/or documented codes of practice |
Testing whether or not something is “partially outside” would not be useful in legislation – so long as, say, 1% of it was within (with 99% outside) would be sufficient to meet the requirement of “partially outside”.
I note that Standards Australia defines performance-based and prescriptive standards as follows:
Performance Based Standards—have their requirements expressed in terms of performance, i.e. outcomes to be achieved. This approach leaves freedom for the development of innovative technical methods to meet the requirements of the Standard.
Performance Based Standards include the criteria, testing or other approved form of verification required to assess performance and to ensure consistency across the solutions developed to meet requirements.
For example, a requirement for a hypothetical wall plug suitable for hanging a mirror might state ‘The wall fixing shall support a weight of 40kg when tested in accordance with the test method in Appendix A.’ This leaves the manufacturer(s) the option of how they design the wall plug – nylon, brass, chemical and so on, as long as it supports the weight.Prescriptive Standards—express requirements in precise, often quantitative, terms. This leaves little opportunity to depart from the specifications in the Standard.
Using the hypothetical wall plug example again, a Prescriptive Standard might state ‘The 40kg wall fixing shall consist of a 2cm expansion case in accordance with Figure 1, together with a ¼in. Whitworth mild steel zinc plated nut and matching 3cm threaded hook in accordance with Figure 2’.
Therefore, I suggest that a practical way to distinguish between these categories of engineering problems is:
- For broadly-defined engineering problems, “only in accordance with a standard (performance-based or prescriptive)”
- For well-defined engineering problems, “only in accordance with a prescriptive standard”.
The current Act
The current Act s67 requires that:
(1) A person must not provide professional engineering services in a particular area of engineering unless the person is—
(a) registered as a practising professional engineer in that area; or
(b) providing the professional engineering services under the direct supervision of a person who is registered as a practising professional engineer in that area.
Where:
professional engineering service means an engineering service that requires, or is based on, the application of engineering principles and data—
(a) to a design relating to engineering; or
(b) to a construction, production, operation or maintenance activity relating to engineering—other than an engineering service that is provided only in accordance with a prescriptive standard;
So everything above ‘only in accordance with a prescriptive standard’ (a well-defined engineering problem, engineering associate work) is included in the definition of a professional engineering service (that must be performed by a registered professional engineer, or under the direct supervision of a registered professional engineer).
In summary, the Act requires:
- Engineering technologists to only perform engineering associates’ work, unless directly supervised by a professional engineer
- Professional engineers to perform engineering technologists’ work, in addition to their existing work.
Won’t using professional engineers to perform engineering technologists’ work give better outcomes?
Consider the following case study from Keefe and Potosky (1997). A large pharmaceutical company had a quality control problem. When investigated, they found that it was caused by the lab technicians (equivalent to engineering associates). They decided to stop the lab technicians’ apprenticeship program and, instead, recruit technicians with associate’s degrees (a 2 year degree, equivalent to what the International Engineering Alliance would expect for an engineering associate) from a community college:
As management had hoped, the community college-trained lab technicians did improve quality control. These lab technicians understood the importance of precisely followed procedures and detailed documentation. Encouraged by their success, management decided to recruit people with more advanced degrees to be technicians. If an associate’s degree was good, then logically, a bachelor’s degree would be better; a master’s better still; and a doctorate would be best. Because of the company’s reputation as a good employer and the union pay scale, management was able to implement its upgrading plan. The company even recruited Ph.D.’s, mainly foreign-born scientists, into the bargaining unit. This plan proved disastrous. In Quality Control these more advanced degree-holders found their work boring, routine, and even demeaning. Once they realised that it would take at least three to five years to get a promotion, many of them expressed their intense displeasure with everyone, and many quit.
The case study also describes the pharmaceutical company removing the apprenticeship program for skilled tradesworkers and using the community college programs instead. Again a disaster.
It is important to match the education level with the work. Too low is a problem – e.g. the apprenticeship system for lab technicians. Too high is a problem – e.g. Ph.D.’s for lab technicians and community college for skilled tradesworkers.
Using professional engineers to perform engineering technologists’ work won’t give better outcomes.
Recommendations
The Act should be updated (and possibly renamed) to recognise and assess engineering technologists, as well as professional engineers.
Engineering technologist work can be defined as “an engineering service that is provided only in accordance with a standard (performance-based or prescriptive)”.
The Queensland Professional Engineers Act 2002 should also be updated for consistency.
References
Keefe, J. & Potosky, D. (1997). Technical Dissonance: Conflicting Portraits of Technicians. In S. R. Barley & J. E. Orr (Eds.), Between Craft and Science: Technical Work in U.S. Settings (pp. 53-81). Cornell University Press.