Expired Licence, Continued Signing and an Upgrade Request
Mrs Adaeze holds an HND in Mechanical Engineering (2016) and was registered as an Engineering Technologist in 2018. Her practising licence was last renewed for 2021 and expired on 31 December 2021; she did not renew in 2022, 2023 or 2024. She continued to work for an HVAC contractor, signing ductwork and equipment selection drawings and supervising two technicians. In November 2024 a client complained that a chilled-water installation failed within six months; the drawings bear her signature and a stamp with an expired licence number. She now applies to renew, asks that her 2021-2024 work be accepted as experience, and requests upgrade to Engineer because she has seven years' experience and a postgraduate diploma in project management. She says she was too busy to renew and that her employer told her the licence was a formality.
1. What is the regulatory status of Mrs Adaeze's work from 2022 to 2024, and how should the registrar treat her claim for experience during that period?
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Her licence expired on 31 December 2021. From 1 January 2022 she was not entitled to practise or to describe herself as a licensed Engineering Technologist. Signing and stamping drawings, supervising technicians and holding out through an expired stamp are breaches of the registration and practice provisions, even if the employer called renewal a formality. The fact that she was previously registered is mitigation, not a defence. The expired stamp is particularly serious because clients rely on it as evidence of current registration.
The registrar should open a file, invite her written explanation, and consider whether the 2021-2024 work should be audited. Her claim for experience during that period cannot be accepted at face value: unlicensed practice is not qualifying experience, and any work she did should be reviewed for public-safety risk. If the installation failure is linked to her signed design, a technical investigation should precede any disciplinary decision.
2. How should the renewal application and the client complaint be handled?
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Renewal should not be granted automatically. The registrar should require: (a) the completed renewal form and prescribed fee; (b) evidence of CPD for the period, or a remediation plan if CPD is deficient; (c) a written explanation of the lapse and of the work done while unlicensed; (d) an audit of the drawings she signed from 2022 to 2024, prioritising the failed installation; (e) a late-renewal penalty if the regulations provide for one.
A reasonable decision is conditional renewal for one year, with a warning, a requirement to complete a refresher course in HVAC design and professional ethics, and random audit of her stamped drawings. If the investigation shows she signed work outside her competence or concealed the lapse, refer the matter to the disciplinary tribunal. Renewal should not be used to erase the prior unlicensed practice; the licence can be restored while the complaint is still investigated.
3. Should her request to be upgraded to Engineer be granted on the present record?
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The upgrade request should be refused on the present record, without prejudice. Registration as an Engineer requires an accredited engineering degree or an equivalent recognised qualification, plus the required experience and assessment. An HND plus seven years' experience and a postgraduate diploma in project management does not automatically meet that standard; the diploma is not an accredited engineering degree, and experience cannot substitute for the academic threshold unless the Council has a specific equivalence route.
The registrar should tell her in writing which route is open: an accredited B.Eng or B.Sc Eng, a Council-approved conversion or top-up programme, or any equivalence assessment the Council publishes. She should also be warned that applying for a title she does not hold, or using Engr. before registration, would be a separate breach. Meanwhile, her technologist renewal and the complaint should be resolved first, because an upgrade application cannot be used to divert attention from the lapse.