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Fabricator: Delegated Steel Connection Design in State of Georgia

Fabricator: Delegated Steel Connection Design in State of Georgia

Fabricator: Delegated Steel Connection Design in State of Georgia

(OP)
Does anyone have experience doing delegated structural steel connections in the state of Georgia, USA? I am looking to see if I am eligible to apply for a GA PE license and be the lead engineer conducting delegated steel connection design on a couple of big projects the sales department recently won. I will NOT be the EOR, just a design engineer for the contracted steel fabricator.

I have NOT passed any version of the SE exam (only the 8-hour PE exam), and therefore am not eligible for Georgia's "new" SE designation (https://seaog.org/articles/se) or to obtain a PE and work on the "EOR design side" on what the new Georgia laws indicate are "designated structures" (https://rules.sos.ga.gov/GAC/180-2-.04?urlRedirect...).

I am licensed in 5 other states, in which I practice structural steel connection design for a fabricator. The company conducts business in accordance w/ "Option 3" from the AISC Code of Standard Practice (https://lsc-pagepro.mydigitalpublication.com/publi...). We are aware full responsibility belongs to the project owner's EOR, but is that sufficient to permit me to practice as their delegated connection designer? All of my sketches, calcs, shop-drawings, etc. are always submitted to the EOR for approval.

I reached out to the State of Georgia Board of Professional Engineers and Land Surveyors for comment, but never received a response.

Reading the lawyer language and contractual verbiage has given me doubts (and a headache), and any input is appreciated.

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

I am licensed as a PE and an SE in GA. If you are licensed in 5 other states, you will likely meet the requirements for licensure by comity as a PE in GA. You will be required to submit an application for licensure by comity and you will need a NCEES record. I think the process also still involves endorsements by other PE's, copies of college transcripts, verification of exams passed, verification of existing license in home state, etc.

Without an SE license, you will certainly be restricted from serving as EOR for "designated structures", and by my reading of the rules, you also cannot "engage in the design or analysis of designated structures", unless under the responsible charge of an SE, of course. As a specialty engineer responsible for delegated designs, I do not think you will be considered to be under the responsible charge of the EOR, so you will not be able to "engage in the design or analysis of designated structures."

The vast majority of buildings are not "designated structures" though, so not having an SE license may not impact your work very often.

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

(OP)
I received an interesting response from the Structural Engineering Association of Georgia (SEAOG) regarding the matter. The state board itself hasn't gotten back to me either time I've inquired about this specific issue. I guess government agencies aren't as interested in helping out:

SEAOG is not the authority on licensure in the state of Georgia. We are only a group of practicing Structural Engineers who, like you, are beholden to the laws, rules, and regulations set by the government of Georgia. In Georgia, it is the PELS Board (Georgia Professional Engineers and Land Surveyors Board) who governs licensure. SEAOG has written several articles to explain our understanding of the licensure system in our state, based on input from the PELS Board and other sources. Our comment regarding component design is founded in State Rule 180-2-.04, which defines the practice of "structural engineering". These articles, as well as this email response, represent our best understanding only, and should not be construed as legal advice or stated facts.

That rule is not explicit that "components of designated structures" are exempt from SE licensure, though. The only hint on this one comes from 80-2-.04 3.b.3, which states "applicants who engage in the design of structural elements, but will not perform Structural Engineering"...."take the 8 hour...exam". Our recollection from the discussion with a representative from the PELS Board during our Sept 2020 Town Hall meeting as well as an email response from PELS to a similar question is that it was not the PELS Board's intent to require all component design for Designated Structures be by a licensed SE, but rather to enable the SEOR for the building to use his/her judgment in determining the licensure requirements for any delegated/component design and empower the local AHJ to have authority over requirements for their jurisdiction.

Our recommendation would be to confirm licensure requirements for delegated design with both the governing Authority Having Jurisdiction (AHJ) and project SEOR.

Best of luck,

SEAOG

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

GA is my home state. I am not surprised to hear that you have not received a response from the state board. They are very unresponsive in my experience.

Regarding SEAOG's email response to your inquiry, I personally would take a harder line than they have in their response. They are attempting to make an exception for delegated component design in a designated structure, with the caveat that the EOR may have a stricter requirement. I am glad that they at least acknowledge the need for the EOR to have the authority to maintain a stricter requirement for SE licensure to engage in delegated component design in designated structures.

My reasoning is that, without an explicit exception for delegated component design in designated structures, which there does not appear to be in the rules, then the EOR would essentially be forced into a position of responsible charge for the delegated design, despite not actually meeting the requirements for responsible charge.

You've gotta love the plain language of the law, huh?... lawyers...

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

OK, I just reread rule 80-2-.04 3.b.3 referenced in SEAOG's response to you. In my opinion, they are wrong in thinking that part of the rule opens the door for an exception for delegated component design in designated structures. They left out the last part of the sentence which says "applicants who engage in the design of structural elements, but will not perform Structural Engineering as defined in Paragraph (2). Paragraph 2 is where it defines structural engineering as "engage(ing) in the design or analysis of designated structures". The definition is not restricted to serving as the EOR, it plainly says "engage(ing) in the design or analysis of designated structures". To me, this applies to all manner of engaging in the design or analysis of designated structures, including delegated component design.

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

(OP)
After mulling it over, I think you're correct. I'll update the thread if I ever get an official response from the Georgia Board of PELS.

It's a little more irritating when you read this clause from the PE license application form. So my slightly older colleague, who only took the regular 8-hour NCEES PE exam (same as me) and got PE licensed in 2010, is eligible to get his SE designation in Georgia, but I'm not. WTF Georgia?

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

I have seen comments made on other forums that even though Georgia law leaves the door open for civil engineers to engage in structural engineering for non-"designated structures", the board does not/will not approve any licensee that states they will engage in any type of structural engineering without first passing the SE.

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

First off, if you're doing the delegated connection design and it's anything beyond pulling tables from the steel construction manual (which, historically, has been what fabricators without an engineer do), you're practicing engineering. So you need an in-state of the project P.E., (in most states, in Illinois it might be an S.E.)

Again, Hyatt regency walkway collapse involved a misunderstanding of a less-than-formally defined connection design, fab thought the engineer did it, eng meant it as a delegated design. Fab didn't have an engineer, and didn't have an engineer design the connection.

Second, is it a P.E. or an S.E. that is required in Georgia for delegated connection design. Interesting question. I've done connection design as the delegated design engineer, but not all that recently (8 years already?) and not in GA. But I do have a 16 hour S.E.

While it's perhaps possible somebody with a Structural-I license from out of state would be able to get an S.E. in Georgia without taking an exam, the likelikood they have 60 months ... never mind. I don't understand clause b. It looks kind of like a grandfather from another state, like, say you had an S.E. in Illinois that you maintained constantly after getting it and had it before the 16 hour exam existed and it wasn't a Structural 2.

To me, the overall SEOR is the one on the hook for special structures, not the delegated connection design engineer (unless the SEOR wants them to have it), as the SEOR is responsible for the overall project and coordination with the delegated engineers.

Two of the big names in connection design are Larry Muir and Bill Thornton, both of (or formerly) of Cives Steel in Roswell, Georgia. Call them.

RE: Fabricator: Delegated Steel Connection Design in State of Georgia

The issue is not whether you need an SE license to perform delegated connection design. The issue is whether you need an SE license to perform delegated connection design for "designated structures". A PE can serve as a SEOR for other than "designated structures", and a PE can perform delegated connection design for other than "designated structures". Of course, the foregoing assumes designing structures is within the PE's area of competence. The vast majority of structures do not meet the definition of a "designated structure" and can be designed by a PE. Only designated structures require an SE in Georgia.

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