Summary of Public Input: Intentions Paper

Posted on July 24, 2019

The BC Government sought feedback from key stakeholders and the public on the intentions paper from October 30, 2018 to March 4, 2019 to inform the development of policy and regulations for implementing the Professional Governance Act (the Act). During the engagement period, the Ministry of Environment and Climate Change Strategy received 126 submissions through the online response form, by letter, and via email. Engineers and Geoscientists BC has provided the following high-level overview of the input received as it relates to our own key policy areas and encourages registrants to review the full report online.

Practice Rights

  • There was no clear frontrunner for a practice rights model (exclusive scope of practice, overlapping scope of practice, or shared scope of practice with restricted activities) – respondents found benefits and concerns with each, noting that the models must be flexible to evolve with changes in the professions.
  • Five respondents specifically stated that BC should not follow the Alberta approach of two regulatory bodies governing engineering practices.
  • The majority of respondents felt the shared scope of practice with restricted activities model is not appropriate for any sector except the health sector. However, a number of respondents support a single regulatory body governing engineering practices.
  • Eight respondents stated support for the existing Engineers and Geoscientists BC limited licence model for engineering technologists or continuing to use the overlapping scope of practice model.
  • Many respondents provided thoughts on the challenges of ensuring professionals “practice in their areas of competency and know their limitation.” These respondents indicated that substantial theoretical education combined with practice experience is necessary to be able to understand these limits.
  • Respondents want to see risk-based exemptions that do not result in unregulated persons practicing within a regulated scope.

Corporate Regulation

  • Many respondents supported the corporate practice model proposed by Engineers and Geoscientists BC.
  • There was broad support for Engineers and Geoscientists BC to be the first to apply the model among the five regulators.
  • Generally, respondents were split between support for applying a consistent model and applying different iterations across professions.
  • A number of responses addressed whether government functions should be exempt as firms, with the majority supporting no exemptions but acknowledging that further engagement on this topic is needed.
  • Responses were evenly split on the regulation of sole proprietors as firms. Several associations and regulatory bodies emphasized that regulation should apply to sole proprietors.
  • Respondents support regulatory alignment across professions for multidisciplinary firms.

Declarations of Competency and Conflict of Interest

  • Many of the responses support Engineers and Geoscientists BC’s position on declarations – that they should be risk based and use existing systems and documents to prevent duplication.
  • Numerous responses share our organization’s concern about the administrative burden involved with implementing declaration requirements.
  • There is broad support for an electronic filling system for declarations, transparency of declarations, and government leadership in administration.
  • Many respondents identified that the current signed and sealed project documentation is sufficient, in combination with annual filing of declarations through regulatory bodies.

Next Steps

Generally, we were pleased to see a number of our positions supported through public feedback. Engineers and Geoscientists BC continues to advance our positions on the three regulation topics with government and are actively engaged in working with the Office of the Superintendent of Professional Governance towards effective implementation of the new legislation. We continue to emphasize that any changes must benefit the overall public good and follow the principle of Right Touch Regulation–using the right amount of regulation to achieve the intended outcome; no more and no less.

Learn More

Read the full report from the Office of the Superintendent of Professional Governance: Regulations Consequent to the Professional Governance ActSummary of Public Input in Response to the 2018 Intentions Paper.

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