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Engineers Canada submits comments to government on wastewater systems effluent, public service licensing


In late October 2020, Engineers Canada submitted recommendations to the federal government on two separate topics—wastewater systems effluent regulations, and licensing of employees performing engineering work in the federal public service.

In response to the government’s consultations on amendments to the Wastewater Systems Effluent Regulations (WSER), Engineers Canada submitted comments in October to Environment and Climate Change Canada. While the current WSER delineates that methods of estimation are based on generally accepted “engineering principles,” consistent standards for engineering practices are not defined in the regulations. Moreover, provinces have regulations that govern wastewater discharges to ground and surface waters that are often more stringent than the federal standards. For these reasons, Engineers Canada noted that the development of professional standards of practice in collaboration with Engineers Canada and provincial engineering regulators could support WSER implementation.

In particular, Engineers Canada also included three recommendations for the federal regulations:

  1. That the regulations be expanded to include that all wastewater systems work—including, but not limited to, transitional and temporary authorization—must be done in accordance with sound engineering principles.
  2. That all engineering work relating to wastewater systems must be approved by a professional engineer.
  3. That consideration be given to the development of national professional standards of practice to support WSER implementation.

In late October, Engineers Canada also submitted a letter to the Honourable Jean-Yves Duclos, President of the Treasury Board, highlighting concerns about federal departments and agencies that advertise engineering positions within the public service, specifically in the engineering sub-category EN-ENG, but do not make engineering licensure a requirement. The formal guidelines issued by the Treasury Board of Canada Secretariat for positions classified as EN-ENG do not make occupational certification a requirement across all EN-ENG positions in federal departments, creating inconsistent criteria for these positions across the federal public service. In those positions where certification is required, the minimum standard refers only to eligibility for certification as a professional engineer in Canada but does not require an applicant to have applied for licensure or to be registered with one of the 12 Canadian engineering regulators. This places public safety, as well as ethical and professional accountability for engineering work, at risk.

Engineers Canada’s letter calls on the Treasury Board of Canada Secretariat to work with federal departments to ensure that engineering licensure is a requirement for all EN-ENG positions within the public service.

“Professional engineers are held publicly accountable for their work,” the letter states. “These layers of accountability and transparency help keep Canadians safe. When postings for EN-ENG positions do not require a candidate to be a professional engineer or at least registered with their provincial regulating body as an engineer-in-training, we will continue to raise our concerns.”

Both submissions are available in full on Engineers Canada’s Government Submissions webpage.