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HomeMy WebLinkAbout80-595 BakowiczTO: RE: Status of Engineers FACTS: DISCUSSION: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 February 21, 1980 ADVICE OF CHIEF COUNSEL John R. Bakowicz, P. E. RD #2, Box 348 -E Sunbury, PA 17801 Advice # 80 -595 On February 6, 1980 John R. Bakowicz, Professional Engineer, wrote this Commission requesting an advisory opinion concerning the status of engineers who are not "township engineers," "borough engineers," or engineers hired on a regular basis, but rather those engineers hired only on a "per job basis" by municipal entities and private clients. Mr. Bakowicz contends that the Statement of Financial Interests is in conflict with the Code of Ethics of Engineers and, therefore, exempts him from any disclosure requirement. The issue is whether an engineer hired only on a per job basis, as opposed to being designated as a regular muncipal engineer is covered as a public employee. The second issue is whether the Code of Ethics for engineers exempts them from requirements of the State Ethics Act. Where an engineer is employed only for a particular project and is not the regular engineer employed by a particular governmental body, that engineer or engineering firm is not considered a public employee and is not subject to the State Ethics Act. Where, however, the engineering firm is designated as the township engineer or borough engineer, for example, the Code of Ethics relating to engineers does not exempt them from any requirements of the State Ethics Act. Engineers are no more exempt from ethical standards than attorneys. Lowery, 79 -64. An engineering firm cannot avoid the State Ethics Act by negotiating a contract on a per job basis when in reality it is employed on a continuing basis from one project to the other. The nature of suctr employment would be deemed to be that of township engineer, regardless of the wording in any contract. John R. Bakowicz, P. E. February 21, 1980 Page 2 CONCLUSION: DRM /rdp -2 An engineer or engineering firm which is employed exclusively on a "per job" basis by a governmental body, and is not normally associated with that governmental body in the representation of it for engineering work is not a "public employee" and is not subject to the disclosure requirement of the State Ethics Act. The Code of Ethics with respect to engineers does not exempt a township engineer, borough engineer, or other engineer associated with the governmental body from filing a Statement of Financial Interests. Pursuant to Section 7(9)(ii), this advice is a complete defense in any enforcement proceeding initiated by the Commission, and evidence of good faith conduct in any other civil or criminal proceeding, providing the requestor has disclsoed truthfully all the material facts and committed the acts complained of in reliance on the advice given. A personal appearance before the Commission and a formal opinion will be issued upon your request if you feel this reply does not suffice. This letter is a public record and will be made available as such. DAVID RITTENHOUSE�MORRISON Chief Counsel