Lapsed Practising Licence on a Donor-Funded Irrigation Bid
GreenAcre Engineering Ltd, a COREN-registered engineering firm in Kaduna, is preparing a bid for a 450-hectare drip irrigation scheme financed by a multilateral donor in Katsina State. The bid requires a lead design engineer with a current practising licence and a firm registration certificate. The designated lead, Engr. Bello, has not renewed his licence for 14 months, although his name still appears on the firm's letterhead and on the sealed hydraulic drawings. The hydraulic design was actually produced by a graduate engineer who joined eight months ago and is not registered. The firm's quality-assurance manager is a registered mechanical engineer with no agricultural or irrigation experience. Bid submission is in ten days; the managing director proposes to submit as-is because 'the firm's certificate covers the bid' and to renew Bello's licence afterwards. A junior engineer objects.
1. Assess the bid as proposed against COREN registration and practising-licence requirements. Identify each breach and who bears responsibility.
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Firm registration is not a substitute for personal licensing. A registered engineering firm may bid and practise only through individuals who hold the appropriate registration and a current practising licence. The firm's certificate does not authorise an unlicensed person to sign or seal engineering documents.
Engr. Bello. His practising licence expired 14 months ago. Signing and sealing the hydraulic drawings, and allowing his name to remain on the letterhead as lead, amounts to holding out and practising without a licence. Renewal after submission would not cure the position at the time of signing; licences are not ordinarily backdated to validate earlier work.
The graduate engineer. A graduate engineer may contribute to design under supervision, but cannot act as the lead designer or sign off drawings requiring a registered engineer. The file must show review and approval by a registered engineer competent in irrigation. At present it does not.
The quality-assurance manager. Registration alone is insufficient; competence must match the work. A mechanical engineer with no irrigation experience cannot provide the required technical assurance for hydraulic design, pump selection and system balancing.
Responsibility. The managing director is responsible for the submission decision; Bello for signing while unlicensed; the firm for allowing the arrangement. The junior engineer should not sign or assist in misrepresentation.
2. Advise the managing director on lawful options before the ten-day deadline and the risks of submitting as-is.
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Lawful options. First, replace the lead with a currently licensed agricultural or irrigation engineer, either from within the firm or engaged as a named sub-consultant, and have that engineer review and sign the design. Second, have the graduate engineer's calculations independently checked and approved by that registered engineer, with the review recorded. Third, if Bello's renewal can be completed before submission, he may sign only after the licence is issued; renewal cannot be assumed. Fourth, ask the donor whether a short extension is possible, or withdraw and bid for a later package.
Risks of submitting as-is. The bid may be rejected or the firm disqualified for failing a mandatory requirement. A donor may debar the firm for misrepresentation. Bello and the firm may face enforcement action for unlicensed practice and use of a seal. The sealed drawings create personal and corporate liability if the scheme later fails. The firm's insurance position may also be affected.
Practical point. The managing director should not treat the ten-day deadline as a reason to compromise. A compliant bid with a properly licensed lead is stronger than a bid that depends on a document that cannot be defended. If no licensed lead can be secured, the honest course is not to submit.
3. What should the junior engineer do when the managing director insists on submitting as-is?
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Raise it in writing. The junior engineer should set out the specific facts: Bello's lapsed licence, the absence of a registered lead, the graduate engineer's role, and the relevant bid requirement. The note should go to the managing director and, if the firm has one, the quality-assurance manager and board or ethics contact.
Do not participate. The junior engineer should decline to sign, seal, witness or otherwise support a false declaration. This is not insubordination; it is a professional obligation not to assist unlicensed practice or misrepresentation.
Escalation. If the firm proceeds, the engineer should consider reporting to COREN. The report should be factual and supported by documents. The engineer should also check whether the donor has a whistleblowing channel, since donor funds are involved.
Protection and proportionality. The engineer should keep copies of communications and seek advice if threatened with dismissal. Reporting should be a last resort after internal escalation, unless there is imminent risk to the public or the misrepresentation is about to be submitted. The guiding principle is that the engineer's duty to the public and the profession is not displaced by an employer's commercial pressure.