The Base Commissioning/ Engineering Argument

1.  As defined by ASHRAE, commissioning is a standardized process of specified tasks:
1. Per ASHRAE Guideline 0: “The Commissioning Process is a quality-oriented process for achieving, verifying, and documenting that the performance of facilities, systems, and assemblies meets defined objectives and criteria”
2. Most of the individual tasks that comprise the commissioning process meet the definition of “engineering” found in state/ provincial statutes and therefore are required to be regulated by those engineering statutes
3. All state and provincial statutes require a licensed professional engineer (PE) to be in responsible charge of engineering tasks
1. Therefore, when executing the commissioning process, a PE must be in responsible charge of the tasks which meet the definition of engineering.  In effect, this requires a PE to be in responsible charge of the entire commissioning process.

1. By law, engineers may only practice within their area/ field of expertise with defined penalties and loss of licensure in place to safeguard the public's health, safety, and property. 
1. As such, projects requiring commissioning of multiple disciplines such as architectural, electrical, mechanical, structural, etc will require and engineer/ architect to be in responsible charge of each discipline.
2. Because commissioning is only a defined process of engineering tasks, state level testing and licensure of the commissioning process does not make sense and is not required.  State level testing and licensure of engineering IS required and accomplished through PE licensure.
3. Cx certifications from organizations such as ASHRAE and BCxA, demonstrate knowledge of the PROCESS but do not replace the requirement for a PE to be in responsible charge of the engineering tasks that comprise the process of commissioning.
4. MOST IMPORTANTLY.  Nothing excludes qualified technicians, lay people, graduate engineers, etc, from supporting or executing the individual tasks that comprise the commissioning process.  AGAIN, qualified technicians, tradespeople, etc can commission engineered systems and equipment.  HOWEVER, by law, a licensed PE must be in responsible charge.