Subject: Comment on 2026…

Subject: Comment on 2026 OSIM Draft Review – Section 2.1.2 Qualifications Required for Inspections of MTO Structures

I am writing to provide feedback on the proposed inspector qualification requirements outlined in the 2026 OSIM draft.

While maintaining high standards for bridge inspection is essential for public safety, the current direction appears to place unnecessary emphasis on formal design-focused credentials rather than demonstrated inspection experience. In practice, many transportation authorities successfully rely on competency-based frameworks that prioritize hands-on inspection experience, mentorship, and progressive responsibility over strictly requiring engineers with specific design designations.

Across North America, numerous agencies allow inspectors to qualify based on a combination of experience, training, and proven field competence. These models recognize that the core function of an inspector is fundamentally different from that of a designer. Inspection requires keen observational skills, familiarity with deterioration mechanisms, and practical judgment developed through repeated field exposure. These are competencies that seasoned inspectors—particularly career bridge inspectors—develop over time and often exceed those of engineers who may not regularly work in inspection roles.

Restricting OSIM inspections to engineers holding specific design certifications such as CET or EIT risks narrowing the talent pool and undervaluing experienced inspectors whose primary expertise lies in inspection rather than design. It may also inadvertently encourage career progression away from inspection roles, as individuals seek credentials that shift their focus toward design or management, rather than remaining in the field where their experience delivers the greatest value.

From having a rotating position of inspector within a ministry or private company there are large costs associated with the presence of the professionals in the field. There will be a continuous brain drain from the inspection pool as professionals like Engineers, CET and EIT move to a more office based work style and in turn a new group will need to be taught about the inspection of structures possibly weakening the ability to catch critical defects.

Career inspectors provide continuity, institutional knowledge, and consistency in condition assessment—qualities that are critical to long-term asset management. Their contributions should be recognized and supported through a framework that emphasizes experience-based competency, structured training, and ongoing professional development, rather than credential-based exclusion.

I encourage consideration of a more balanced qualification model that:

- Recognize extensive inspection experience as a primary qualification pathway
- Support mentorship and supervised progression for developing inspectors
- Maintain rigorous training and certification requirements specific to inspection work and the safety fields that bridge inspection require (OGRA OSIM Course, AREMA Inspection Module, Working at Heights, Confined Space, Working around water, etc...)
- Value and retain career inspectors as subject matter experts in their field

Such an approach would align with best practices across multiple jurisdictions while preserving safety, improving workforce sustainability, and ensuring that inspection quality remains grounded in real-world expertise.

Thank you for the opportunity to provide input on this matter.