After reading section 140, it appears that all licensees could practice engineering or surveying without a license as long as the work was proper and within their education and experience.  How will the board discipline non-engineers from practicing engineering if their work is approved by other agencies (i.e., the VDH) and was not "negligent?"  I think Section 140 should be expanded to say that no one is allowed to practice engineering, regardless of whether they did the work properly and it was within their education and training unless they are licensed as an engineer.  An example might be an employee of a manufacturer who is well trained and educated in the use of that particular manufacturer's device.  The employee still designs and inspects a system over 1,000 gpd, which is clearly the practice of engineering.  I don't think Section 140 would allow the board to discipline the licensee.