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Approver on professional documents

Approver on professional documents

Approver on professional documents



The following can be found in the rules of Arizona Board (link to full text below if you're interested).

"A registrant shall not sign, stamp, or seal any professional documents not prepared by the registrant or a bona fide employee of the registrant."

I'm struggling a bit with the word "or" in that statement. Does that mean an Arizona PE can only sign (signature only with no seal) as an "approver" for specifications, plans and drawings if they were prepared by the PE or under his direct supervision? I am asked to provide technical review of operations plans/procedures for the company and sign off as one of the approvers to show the document passed through me. Since the documents were not prepared by myself or under my direct supervision, would I - as a registrant - be in violation? I read the definition for professional documents in the rules and the plans/procedures would meet that definition majority of the time.

I'm interested in how other reasonable people would interpret that statement. After all, Board members are reasonable and professional people as yourself and not lawyers (usually).

Thank you in advance.


RE: Approver on professional documents

suggest reading the definitions

R4-30-101. Definitions
3. “Bona fide employee” means:
a. Any person employed by a town, city, county, state,
or federal agency working under the direction or
supervision of a registrant;
b. Any person employed by a business entity and
working under the direct supervision of a registrant
who is also employed by the same business entity; or
c. Any person working under the direct supervision of
a registrant who:
i. Receives direct wages from the registrant;
ii. Receives contract compensation from the registrant; or
iii. Receives direct wages from the project prime
professional who has a contract with another
registrant and whose work product is the
responsibility of the latter registrant.

RE: Approver on professional documents

Thanks cvg. I read that definition. That's why I asked if the documents need to be prepared by myself or under my direct supervision. Did you read the definition of a bona fide employee differently than I did?

RE: Approver on professional documents

I think you might be reading too far beyond the text here. The statement you quote is dealing with a person issuing designs/documents where they would be viewed as designed by that person and the person is implying or stating that they are the engineer-of-record of that design.

In your case, you are not "posing" as an engineer claiming to have designed this thing you are reviewing. You are simply reviewing it in a quality assurance/control role, which is a very different function from the one the board law is trying to control here.

As long as your signature is clear that it was for QC/QA processes then you would be OK as I see it.
You might call the board and pass that by them as well. Each state has its own perspective.

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RE: Approver on professional documents



[b]R4-30-304. Use of Seals
A. A registrant shall place a permanently legible imprint of the
registrant’s seal and signature on the following:

You could interpret this section as making a distinction between the combination of "seal and signature" and signature only.

RE: Approver on professional documents

I would argue that if in the act of signing the document you can direct changes to your satisfaction, then the document was prepared under your direct supervision, regardless of where you and they fit in the company's org chart.

RE: Approver on professional documents

In most cases, an engineer reviewing a document can make comments, corrections, etc.
But ultimately, for a specific design of an entity, there must be one individual who is the ultimate licensed engineer-of-record.

If other licensed engineer reviews and makes comments/corrections, it is still up to the EOR to decide if those comments/corrections are valid and incorporate them accordingly.
This type of review does not usurp the role of the original EOR and the reviewer does not have to, nor should, stamp/sign the documents as though they were the EOR.

In other words, there's always one person who sits at a desk with "The buck stops here" on it, on any particular project.

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RE: Approver on professional documents

Thank you all for your inputs. Much appreciated.

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