Control systems engineering: Are PE stamped designs a requirement?

Professional engineering licensure for control system designers, engineers, and integrators is always a topic that can bring forth heated arguments both for and against licensure. The purpose of this article is to put forth the facts and let the readers determine if professional engineer (PE) designed control systems are a requirement for their systems and facilities.

02/24/2015


Professional engineering licensure for control system designers, engineers, and integrators is always a topic that can bring forth heated arguments both for and against licensure. The purpose of this article is to put forth the facts and let the readers determine if professional engineer (PE) designed control systems are a requirement for their systems and facilities.

First some background, the practice of engineering is a regulated profession, just as doctors, attorneys, and many other professionals are. The practice of engineering is regulated because it has the potential to effect public health, safety, and welfare. Engineers who design public works (buildings, roads, bridges, and utilities) that the general public interacts with, or whose work product requires the approval of government agencies, are required to stamp their drawings and plans to certify the work complies with accepted consensus standards and was performed and supervised by a registered PE. Stamped PE drawings are typically the work product of civil, structural, mechanical, and electrical engineers. In the past, the control system designs behind these works, even in public works facilities, such as water and wastewater treatment plants, were typically not required to be PE stamped and not much thought was given to these systems. Typically the control system vendor/designer/integrator was a 3rd or 4th tier sub to the prime contractor, so not much attention was given to the control system design drawings and software configuration.

This has changed because of the increasing connectedness of control systems, cyber security requirements, and the increased reliance on software to perform safety functions that were once hardwired. In general, there has been an increased awareness that control systems in critical public works, utilities, and industrial infrastructure need the design rigor that comes from having licensed professional engineers sign off on the designs of these systems. Because the licensing of engineers is conducted on a state level, each state has their own PE requirements for control system engineering. Since I reside in South Carolina I am most familiar with the state requirements for S.C. The S.C. Engineering Board in 2007 directly addressed control systems in their definition of engineering.

“The Board has determined that designing control systems is considered the practice of engineering and requires professional engineer licensure. Companies that provide systems integration services that include the design of control systems and selection of system components are considered to be providing engineering services and must have a Certificate of Authorization from the Board. Therefore, those firms must also have licensed engineers who are in responsible charge of that work.”

Practically, this means control system engineering (CSE) firms or integrators delivering control systems in S.C. must have at least one S.C. registered engineer on staff as the engineer of record and the company must be registered as an engineering firm in the State of S.C. Other states’ engineering boards have made similar determinations, but some states have left this question unanswered and up to the end users to decide. Many states also have exemptions for industrial organizations to PE stamping requirements. End users must ask themselves, is this exemption worth taking, considering the additional risks the user assumes?

CSE was first recognized as an engineering discipline nationally in 1992 when the National Council of Examiners for Engineering and Surveying (NCEES) offered the PE exam in CSE. In the 20+ years since 1992, the interconnectedness, complexity, and importance of software have only increased in the area of industrial automation. Because of the increasing complexity of control systems and their increased use as safety systems, many end users and government agencies now require all control system drawings as well as their associated software programs be stamped by a professional engineer. While there is certainly additional cost associated with stamped drawings, the cost is minimal compared with the end users potential liabilities should something go terribly wrong due to a design error either in hardware or software. The requirement for PE stamped control system drawings is something customers should add to their risk analysis when proposing and selecting control system vendors for a project. Simply put, PE stamped control system drawings add another level of checking and assurance that the firm and individuals doing the work are responsible and accountable for the work product they have produced.

This post was written by David Paul. David is an engineering design manger at MAVERICK Technologies, a leading automation solutions provider offering industrial automation, strategic manufacturing, and enterprise integration services for the process industries. MAVERICK delivers expertise and consulting in a wide variety of areas including industrial automation controls, distributed control systems, manufacturing execution systems, operational strategy, business process optimization and more.

MAVERICK Technologies is a CSIA member as of 3/5/2015



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