Stamping of Critical Infrastructure Control Systems

The views expressed here are those of the author and do not necessarily represent the views of and should not be attributable to the National Society of Professional Engineers.

An excellent viewpoint article was published recently inEngineering News-Record, authored by Daniel A. Groves, P.E., regarding the need for licensed professional engineers to be in responsible charge of the design of control systems software for critical infrastructure facilities that potentially impact public health, safety, and welfare or the environment.

More and more, our water treatment facilities, which provide safe drinking water, and our wastewater treatment facilities, which protect water quality, are operated by monitoring and control systems that increasingly perform automated monitoring and process control in the absence of operating staff. The reliability and security of these systems is critical to protect public health, safety, welfare and the environment.

The design of these systems is typically under the overall responsible charge of a licensed professional engineer who is responsible for designing new facilities or modifications to existing facilities. These engineers are typically environmental, chemical, and/or mechanical engineers, and not software or control system engineers. The project engineer often creates a performance specification, which details the needed functions of the control system. Typically, contractors are responsible for providing both the control system hardware and software. This is generally not the area of expertise of the general contractor, nor in many cases of the electrical subcontractor, but rather is provided by a third- or fourth-tier subcontractor. Some design engineers require that the software be stamped by a licensed professional engineer, but many don’t. Upon equipment start-up, the function of the control system is tested to see if the requirements of the performance specification are met, but the software itself, and its reliability and security, are often not under the responsible charge of a professional engineer.

Adequate protection of public health, safety, welfare, and the environment is directly dependent upon the reliability and security of these automated control systems.

The National Council of Examiners for Engineering and Surveying (NCEES) has for years offered a PE exam in control systems engineering, and, beginning in April, 2013, will be offering a PE exam in software engineering, initiated by a consortium of engineering societies, including NSPE. The licensure system now is in place to facilitate the licensure of qualified control systems and software engineers.

Currently, many software systems that operate critical infrastructure facilities are not created under the responsible charge of licensed professional engineers. How do we get from where we are to where we need to be? PE boards can help enforce licensure requirements, but this is often after the fact, and typically in the event of a complaint of the unlicensed practice of engineering. Such complaints are few and far between. What needs to be done? In the interest of protecting public health, safety, welfare, and the environment, engineers writing control system performance specifications need to specify that the hardware and software packages will be stamped by licensed professional engineers. This doesn’t mean that every code-writer in America working on critical infrastructure systems needs to quickly become licensed, but rather that such work is under the responsible charge of a licensed professional engineer. Electrical, control systems, and software engineers will fill the needed gap. We also need to educate and convince infrastructure owners and operators of the critical need for this requirement. That requirement has been the standard of practice in the engineering profession for metal buildings for more than 40 years. We need to specify similar requirements for the design of control systems for critical infrastructure facilities.

Input for this piece has been provided by L. Robert Smith, P.E., F.NSPE; Bernard R. Berson, P.E.,L.S., F.NSPE; Thomas H. Stout, Ph.D., P.E. and Daniel A. Groves, P.E.

Published June 7, 2012 by Craig Musselman, P.E., F.NSPE

Filed under: NCEES, Licensing, Control Systems,

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