Memorandum in Opposition (submitted May 18, 2017)
A 926 Lupardo (MS) // Same as S1440 (Avella)
INDOOR AIR QUALITY PLANS
On behalf of the New York State Society of Professional Engineers (NYSSPE), in furtherance of public health, safety and welfare, we are writing in opposition to the above referenced bill. NYSSPE is a professional trade association representing the interests of its members and more generally the interests of all professional engineers (totaling more than 25,000 licensees in New York State) practicing in all disciplines (civil, structural, mechanical, electrical, geological, environmental, etc.) and practicing in all practice settings (private sector consulting, industry, government, and education.)
The objectives of the legislation, including the improvement of the quality of indoor air in furtherance of worker safety, are laudable. However, the activities required to be undertaken as specified in the legislation, including the formulation and implementation of an indoor environmental plan, the determination that a variance from standards is warranted and/or indoor air investigations, constitute the practice of engineering as defined in Article 145 of Title VIII of the State Education Law and the legislation should expressly require that such work be performed by a duly licensed Professional Engineer.
Representatives of this Society would welcome an opportunity to discuss the concerns set forth herein in greater detail with sponsors, the committee chair, committee members or their staff. We reiterate, however, our request that this bill be held pending amendments to insure that professional engineering services are provided by appropriately credentialed parties with the required level of expertise and experience.
Mark C. Kriss, Esq.
NYSSPE Legislative Counsel
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