A Foreign-Trained Graduate, a Borrowed Seal and a Lapsed Application
Mr. Chinedu Okonkwo returned to Nigeria in 2016 with a B.Eng Civil Engineering from a university in a neighbouring West African country, graduating in 2014. The programme is not on Council's schedule of recognised engineering qualifications, and the awarding institution is not accredited under any mutual recognition arrangement to which Council is a signatory. Since 2017 he has worked as a site engineer and, for the last two years, has prepared and submitted structural drawings for a four-storey hotel to the State Physical Planning Authority. Those drawings carry the seal and signature of Engr. Funmi Adeyemi, whose annual practising licence is current; she states she 'reviewed the drawings once over a weekend' and has never visited the site. Okonkwo's own application for registration, filed three years ago, is pending because he has not sat the professional interview. He styles himself 'Engr.' on site documents, and the consultancy that employs him, BuildRight Associates Ltd, advertises 'in-house COREN-registered engineers' although the firm itself has never been registered as an engineering firm.
1. Identify the regulatory breaches and allocate responsibility among Okonkwo, Engr. Adeyemi and BuildRight Associates Ltd.
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Okonkwo. Two separate breaches. First, using the title 'Engr.' and holding himself out as an engineer while unregistered is misrepresentation, independent of the quality of his work. Second, preparing structural drawings for a building for construction is practising engineering, which requires registration and a current licence. His pending application is not a defence; a pending application confers no interim right to practise.
Engr. Adeyemi. Sealing and signing drawings she did not prepare, and for work she did not supervise, is the most serious item because it defeats the entire purpose of the seal. The seal is a personal certification that the design was prepared or directly supervised by the licensee. A weekend review is not supervision. She is exposed on professional discipline regardless of whether the building performs; if it fails, civil liability follows.
BuildRight Associates Ltd. Advertising 'in-house COREN-registered engineers' while unregistered as an engineering firm misleads the public about the corporate entity's status. The firm also permitted an unregistered person to produce construction documents.
Allocation principle. Do not treat this as one offence with three accessories. Each party breached a distinct obligation: individual title, individual certification, corporate registration. Council should open separate files, because they attract different sanctions and different appeal routes.
2. What is the correct registration pathway for Okonkwo, and what must he stop doing immediately?
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Immediate. He must cease using the title 'Engr.', cease producing or issuing drawings for construction, and cease signing site documents as engineer. He may continue working under the direct supervision of a registered engineer, with his role described accurately (for example, 'graduate engineer, unregistered').
Pathway. Because the awarding institution is not on Council's recognised schedule and there is no mutual recognition arrangement, there is no automatic exemption and no credit transfer by default. The proper sequence is:
- Apply for formal evaluation of his qualification by Council, submitting transcripts, programme content, accreditation status of the programme in its home country, and evidence of the awarding body's recognition there.
- Expect a remediation requirement - typically a Council-recognised postgraduate or conversion programme in civil engineering, or specified examinations - because the degree cannot be assumed to meet the benchmark.
- Accumulate and document post-qualification experience under a registered engineer, with a supervising engineer's countersignature and project records.
- Sit the professional interview (and any prescribed examination) and satisfy the panel on competence and conduct.
- On success, be entered in the Register, then obtain the annual practising licence before offering engineering services.
Advice to give him. The three-year delay is self-inflicted; the file has been dormant because he has not presented himself for interview. He should also be told plainly that a qualification from an unrecognised institution is not disqualifying - it simply means the burden of demonstrating equivalence is his.
3. What should the Planning Authority and Council each do about the submitted drawings and the firm's advertising?
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Planning Authority. The drawings are not properly certified. The authority should not approve for construction on the strength of a seal whose owner did not prepare or supervise the design. The defensible course is to suspend consideration, notify Council, and require re-submission with (a) certification by a currently licensed engineer who either prepared the design or has carried out a documented independent structural review, and (b) that engineer's written confirmation of the supervision arrangement for construction. If work has begun, the authority should require an independent structural check before further construction. The authority's interest is building safety; the registration offence is Council's business.
Council. Three parallel actions. First, an enforcement notice to BuildRight Associates Ltd requiring it either to apply for registration as an engineering firm or to withdraw the claim from all advertising and tender documents, with a stated compliance date. Second, a disciplinary referral in respect of Engr. Adeyemi for improper certification - she is entitled to notice of the allegation and an opportunity to respond before any tribunal step. Third, prosecution consideration for Okonkwo's misrepresentation, weighed against his cooperation and the fact that a disciplinary warning may achieve more.
Sequencing point. The firm's advertising is easily fixed and should not be bundled with the certification issue, which may take months. Bundling lets the firm delay everything by disputing the harder allegation.