Unauthorized Practice or Title FAQs
Below are answers to frequently asked questions about unauthorized practice and misuse of title.
General
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1. What legislation sets out the rules for unauthorized practice and misuse of title?
Part 5 of the Professional Governance Act S.B.C 2018, c. 47 (the “Act”) contains the prohibitions on unauthorized practice and misuse of title.
The Engineers and Geoscientists Regulation, B.C. Reg. 14/2021 (the “Regulation”) contains the definitions applicable to the unauthorized practice and misuse of title prohibitions under Part 5 of the Act. -
2. How do I check if an individual, company, or other legal entity is registered with Engineers and Geoscientists BC?
Our public online directory allows you to search for the registration status of individuals and firms.
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3. How do I submit a concern about unauthorized practice or misuse of title by a non-registrant?
Our webpage on reporting non-registrants sets out how to submit an unauthorized practice or misuse of title concern to Engineers and Geoscientists BC.
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4. What is Engineers and Geoscientists BC’s enforcement process?
When an unauthorized practice or misuse of title concern is submitted to Engineers and Geoscientists BC, we conduct a preliminary review to determine whether a concern appears to be within our jurisdiction to address. If an enforcement file is opened, we investigate the evidence provided and other evidence we are able to obtain independently, and take steps if necessary to bring the individual or firm into compliance with the Act. While most files are resolved without court action, we do have the ability to take action in the Supreme Court of British Columbia to secure compliance and prevent future contraventions of the Act.
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5. How involved will I be? Will you keep me updated?
We triage all new enforcement concerns based on risk and begin working on the highest risk files first. After an enforcement file is opened, we encourage complainants to submit any new evidence or relevant information obtained. However, we do not provide complainants with updates to open enforcement files. If an enforcement file is resolved through court action or by Letter of Undertaking, we will publish the associated documents on our webpage for unauthorized practice and misuse of title notices.
Misuse of Title
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1. What constitutes misuse of title?
Misuse of title occurs when a non-registrant of Engineers and Geoscientists BC:
- Uses one of the following expressly reserved titles:
- “Professional Engineer” or “P.Eng.”
- “Professional Geoscientist” or “P.Geo.”
- “Professional Licensee Engineering” or “P.L.Eng.”
- “Professional Licensee Geoscience” or “P.L.Geo.”
- “Engineer-in-Training” or “EIT”
- “Geoscientist-in-Training” or “GIT”
- Uses any other name, title, or description in a manner implying that they are a registrant of Engineers and Geoscientists BC, associated with Engineers and Geoscientists BC, or are authorized to practice the professions of engineering or geoscience in BC. Examples include:
- Using “Engineer” in combination with an engineering discipline, in combination with another word related to the profession of engineering, or in combination with any language that expresses or implies the right to practice engineering.
- Using “Engineer” on its own if the context of the use expresses or implies a right to practice engineering.
- Use of any title that implies the right to practice geoscience, including “Geoscientist”, “Geologist”, “Geochemist”, or “Geophysicist”.
- Representing yourself as an engineer or geoscientist by applying a current or former registrant’s professional seal, or a representation of a registrant’s seal.
- Using a restricted word in a business name (including a corporation, partnership, or sole proprietorship).
The following table contains examples of titles and indicates who can use them:
Title Registrant Non-Registrant Jamie Smith, B.Eng., B.Sc., BASc, etc. Yes Yes Jamie Smith, Bachelor of Science in Geology (or other engineering/geoscience discipline) Yes Yes Jamie Smith, P.Eng. (Alberta)/Professional Engineer (Alberta)
Jamie Smith, P.Geo. (Alberta)/Professional Geoscientist (Alberta)Yes Yes, but requires registration in another jurisdiction and is only available in very limited circumstances. Does not entitle practice. Jamie Smith, P.Eng./Professional Engineer
Jamie Smith, P.Geo./Professional GeoscientistYes No Jamie Smith, Engineer-in-Training/EIT
Jamie Smith, Geoscientist-in-Training/GITYes No Jamie Smith, P.L.Eng./Professional Licensee Engineering
Jamie Smith, P.L.Geo./Professional Licensee GeoscienceYes No Jamie Smith, P.Eng. (Non-Practising)/P.Eng. (Retired)
Jamie Smith, P.Geo. (Non-Practising)/P.Geo. (Retired)Yes; non-practising registration available for a reduced annual fee – see question 14 No Jamie Smith, Engineer/Jamie Smith, Mechanical Engineer
Jamie Smith, Geoscientist/Geologist/Geochemist/GeophysicistYes No Jamie Smith, Firmware Engineer Yes No Jamie Smith, Structural Engineering
Jamie Smith, Engineering SpecialistYes No Jamie Smith, Geoscience Professional Yes No - Uses one of the following expressly reserved titles:
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2. Can I use the title “Software Engineer” or another high-technology-related engineering title?
Software and computer engineering have been designated as disciplines of professional engineering since 1999 and 1998, respectively, and are currently listed as disciplines of professional engineering under the Regulation.
Non-registrants are prohibited from using titles like “Software Engineer” or other high-technology-related engineering titles such as “Firmware Engineer”, “Hardware Engineer”, “Data Engineer” because they imply that the individual using them is a registrant and that they are authorized to practice the professions of software or computer engineering in BC.
We do, however, recognize that not all software development constitutes software engineering. In some cases, individuals mistakenly use a title like “Software Engineer” when they are not actually engaged in any engineering work. Individuals may have roles more appropriately characterized as a “developer”, “designer”, or “programmer". For more information on software engineering and for help determining whether work constitutes software engineering requiring registration with Engineers and Geoscientists BC, please see our software engineering applicant webpage.
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3. I supervise or manage a team of engineers/geoscientists. What titles can I use?
We recognize that non-registrants can supervise or manage teams of registrants in a business capacity. Non-registrants are permitted to use titles like “Director of Engineering”, “Engineering Manager”, or “Exploration Manager”, provided that their role is purely business in scope (i.e. it does not involve providing any engineering advice or services externally to clients or internally at the firm).
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4. I am not a registrant of Engineers and Geoscientists BC, but I have an educational background in engineering/geoscience. Does that grant me any use of title rights?
The misuse of title prohibitions under the Act apply to all non-registrants regardless of their educational background. On its own, having an educational background in engineering or geoscience does not grant any use of title rights. However, non-registrants are allowed to indicate that they hold a “Bachelor of Engineering”, “Bachelor of Applied Science”, “B.Eng.”, “B.Sc.”, “BASc”, etc.
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5. What are the rules for title use by Engineers-in-Training and Geoscientists-in-Training?
Engineering and geoscience trainees who are registered with Engineers and Geoscientists BC must comply with the use of title requirements under Engineers and Geoscientists BC bylaws 5.5.1 and 5.5.2, respectively. These bylaws require, among other things, that use of a title containing the words ‘Engineer”, “Geologist”, “Geoscientist”, “Geophysicist”, or “Geochemist” (or other forms or abbreviations of them) must include the designation “Engineer-in-Training” (or “EIT”) or “Geoscientist-in-Training” (or “GIT”) in close proximity to the title and given the same or a higher degree of prominence.
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6. What are the rules for title use by Professional Licensees?
Professional Licensees - Professional Licensee Engineering and Professional Licensee Geoscience—who are registered with Engineers and Geoscientists BC must comply with the use of title requirements under Engineers and Geoscientists BC bylaws 5.8 and 5.9, respectively. These bylaws require, among other things, that use of a title containing the words ‘Engineer”, “Geologist”, “Geoscientist”, “Geophysicist”, or “Geochemist” (or other forms or abbreviations of them) must include the designation “Professional Licensee Engineering” (or “P.L.Eng.”) or “Professional Licensee Geoscience” (or “P.L.Geo.”) in close proximity to the title and given the same or a higher degree of prominence.
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7. I am registered as an engineer/geoscientist in another jurisdiction. Does that grant me any use of title rights?
No (with a very limited exception under section 53 of the Act). Registration in another jurisdiction does not grant use of title rights in BC. To obtain use of title rights, you must register with Engineers and Geoscientists BC. If you are a current registrant or licensee with another Canadian Association/Ordre, there is a simplified process which allows you to more easily register with Engineers and Geoscientists BC. Becoming a registrant with Engineers and Geoscientists BC does not affect your status with another Canadian Associations/Ordre.
There is a very limited exception under section 53 of the Act which allows for use of a jurisdictional qualifier such as “P.Eng. (Alberta)”. This exception is only available in a scenario where there is a genuine need to let the recipient of your communication know that you are registered in, for example, Alberta. You cannot utilize the exception in section 53 to engage in engineering work in BC or use the title “P.Eng.” in BC when you don’t have a genuine need for letting someone know that you are registered in Alberta.
For example, it would be appropriate to write “P.Eng. (Alberta)” if you are in BC communicating with a prospective client about work in Alberta. On the other hand, it would not be appropriate to write “P.Eng. (Alberta)” on correspondence to the BC municipality where you have a summer home, commenting on proposed bylaw amendments.
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8. I have applied for registration with Engineers and Geoscientists BC. Does that grant me any use of title rights?
No. Being an applicant for registration (P.Eng., P.Geo., P.L.Eng., P.L.Geo., EIT, or GIT) with Engineers and Geoscientists BC does not grant any use of title rights.
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9. I used to be a registrant of Engineers and Geoscientists BC. Does that grant me any use of title rights?
Former registrants do not maintain any use of title rights. If you do not want to practice, but do want to retain some use of title rights, you can obtain non-practising registration which will allow you to use your designation along with your choice of the qualifiers “(Non-Practising)” or “(Retired)”. The non-practising registration fees is discounted by 75% from the full registration fee.
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10. My job title contravenes the Act, but it was given to me by my employer. Can I still use that title?
No. The obligation to comply with the Act’s misuse of title prohibitions follows the individual who is using the title. If your title contravenes the misuse of title prohibitions under the Act, then you must revise that title, even if it was given to you by your employer.
Unauthorized Practice
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1. What constitutes unauthorized practice?
Unauthorized practice occurs when a non-registrant of Engineers and Geoscientists BC:
- Provides engineering or geoscience advice or services in a scenario that has the ability to impact the safety, health and welfare of the public, including the protection of the environment and the promotion of health and safety in the workplace.
- Engages in the practice of professional engineering or professional geoscience as it was defined in the former Engineers and Geoscientists Act, R.S.B.C 1996, c. 116.
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2. Who needs to be registered with Engineers and Geoscientists BC in order to do engineering or geoscience work?
Individuals and firms (legal entities or combinations of legal entities) must be registered with Engineers and Geoscientists BC in order to do engineering or geoscience work.
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3. What if I am not stamping any work?
Work does not have to be stamped in order to constitute the practice of engineering or geoscience. For example, an unstamped report, email, verbal discussion, or other communication in which the author provides engineering/geoscience analysis or advice could amount to unauthorized practice if done by a non-registrant.
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4. What if my engineering or geoscience work is only used internally at my organization and not prepared for external clients?
Engineering or geoscience work used internally at a firm constitutes engineering/geoscience advice or services. The unauthorized practice provisions under the Act apply to both internal and external (i.e., public or client-facing) engineering or geoscience work. For more information, please see the information bulletin from the Office of the Superintendent of Professional Governance.
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5. I am registered as an engineer/geoscientist in another jurisdiction. Does that grant me any practice rights?
No. However, being a current registrant or licensee with another Canadian Association/Ordre allows you to more easily register with Engineers and Geoscientists BC. Becoming a registrant of Engineers and Geoscientists BC will not affect your status registration status with another Canadian Association/Ordre.
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6. I am registered as a professional geoscientist in Ontario. Can I practice in BC under the temporary practice mobility agreement?
No. The temporary practice mobility agreement between Engineers and Geoscientists BC and Professional Geoscientists Ontario is no longer in effect since the Professional Governance Act came into force on February 5, 2021.
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7. Do I need to register with Engineers and Geoscientists BC if I am working while physically outside of BC for a BC company/project/client?
Yes. If you are providing engineering or geoscience advice or services in respect of a BC company, project, or client while physically located outside of BC, you must register with Engineers and Geoscientists BC.
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8. Do I need to register with Engineers and Geoscientists BC if I am working while physically inside BC for a company/project/client that is outside of BC?
Yes. If you are providing engineering or geoscience advice or services while physically located in BC for a company, project, or client that is located outside of BC, you must register with Engineers and Geoscientists BC.