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Board to seek legal clarity after members flag TDOT signature-and-seal guidance
Summary
Engineers on the board said Tennessee DOT guidance appears stricter than board rules for electronic seals and signature placement on plan sheets; staff will ask legal for an interpretation and circulate proposed language to students and licensees.
During the engineer committee portion of the Feb. 5 meeting, board members discussed apparent differences between the board's rule on electronic seals and Tennessee Department of Transportation (TDOT) guidance for signing and sealing plan sets.
Board member Jason Carter asked whether TDOT's practice of having an electronic seal, signature and date on the title sheet with watermarks (or wet signatures) on remaining sheets conflicts with the board's rule that electronic seals "shall not include the registrant signature or date." Doctor Ash clarified that TDOT signs and seals every sheet, while the board's rule allows sealing an index sheet alone; members agreed the difference might reflect TDOT's stricter procurement requirements rather than an outright violation of board rules.
Staff and board members recommended legal review and suggested that the board draft clarifying guidance: whether licensees may comply with TDOT by signing the title sheet and water-marking remaining sheets, or whether a change in board rules is needed. Chair Frank Wagster and legal staff agreed to circulate proposed language and seek counsel's written interpretation before issuing informal guidance to licensees.
Ending: The committee did not adopt any rule change that day; staff will request legal interpretation and return recommendations to the committee.
