The Expired Seal on a 33 kV Substation Design

Registration and licensing are separate controls. Engr. A. O. remains on the register, but his practising licence is not current. Under the Engineers (Registration, etc.) Act, practising without a current licence is an offence, and signing and stamping engineering documents for a client is practising. The design carries his seal, so the client and the public are entitled to rely on a valid licence at the date of issue.

The managing director’s instruction to send the old number is an instruction to misrepresent his status to a client. Complying would convert an administrative lapse into a false statement, expose the engineer to disciplinary action and possible prosecution, and expose the firm to loss of registration and civil liability. Professional obligations to public safety and honesty override an employer’s commercial instruction. The engineer should refuse in writing, explain the legal risk, and propose a compliant route: disclose the lapse, stop issuing further stamped documents, and arrange for a currently licensed engineer to review and re-issue the design.

The priority is to protect the client and the public while regularising status.

1. Disclose promptly and in writing. The engineer should tell the client that his licence lapsed, give the true dates, and confirm which documents he signed. Concealment would compound the original breach.
2. Suspend stamped issue. No further drawings, calculations or certificates should be sealed by him until a current licence is restored.
3. Independent review. A currently licensed engineer, acceptable to the client, should review the substation design, including fault level, protection coordination, earthing and cable sizing. The review should be documented, and the reviewed drawings re-issued under a valid seal.
4. Regularise. He should apply for renewal or reinstatement, pay any outstanding fees and complete the required professional development, keeping evidence.
5. Firm registration. The firm should confirm its own COREN registration status and provide the client with accurate information. If the firm’s registration depends on a licensed engineer, the lapse may also affect that status.
6. Record and report. The firm should record the corrective action and consider notifying its insurer and COREN as required. The transformer procurement should be checked against the reviewed design before fabrication proceeds.

The firm’s exposure is both regulatory and commercial. Regulatorily, it allowed an unlicensed engineer to issue design documents and then proposed to misrepresent his licence number; that can attract enforcement against the firm, not just the individual, and may affect its registration as an engineering firm. Commercially, the client may suspend payment, demand re-design at the firm’s cost, or claim for delay if the transformer order must change. If a defect later causes failure, the firm’s professional indemnity position is weakened by the licensing breach and by the misleading instruction.

The lessons are procedural: maintain a licence register with expiry dates and a 60-day renewal trigger; assign a named officer for renewals, with a second check; block stamp issuance when a licence is not current; require partner approval before any representation about registration status; and include licence status in project kick-off and document-control checks. A firm that treats licensing as an admin detail will eventually face exactly this conflict between a client payment deadline and a regulatory prohibition.