August 19, 2021

National Institute of Standards and Technology

100 Bureau Drive

Stop 2000

Gaithersburg, MD 20899

RE: The National Society of Professional Engineers Response to Docket ID 

No. NIST-2021-0004, Artificial Intelligence Risk Management Framework

On behalf of more than 23,000 members of the National Society of Professional 

Engineers, these comments are submitted in response to the National Institute of 

Standards and Technology!s request for input on the "Artificial Intelligence Risk

Management Framework.”

The National Society of Professional Engineers is committed to creating a world 

where the public can be confident that engineering decisions affecting their lives 

are made by qualified and ethically accountable individuals. It is the policy of 

NSPE to support emerging technologies in a manner that protects the public 

through rigorous development, testing, and deployment of emerging technologies. 

The rationale for this position is rooted in a professional engineer!s ethical

obligation to hold paramount the public health, safety, and welfare.

With this role in mind, the National Society of Professional Engineers 

recommends NIST include, as part of its risk management framework for artificial 

intelligence, a licensed professional engineer or an individual qualified by 

education, examination, and experience through a reputable professional or 

industry organization. This individual would be responsible for making decisions 

related to protecting the public, including those who would use or potentially be 

affected by an AI application. Oversight responsibility should include having the 

authority to approve or reject the process, methodology, or other characteristics of 

the specific AI project. Having a credentialed individual to ensure these 

considerations are made can reduce risk that an artificial intelligence application 

will fail.

A professional engineer or properly credentialed individual would also be 

responsible for mitigating bias, making ethical considerations, and managing 

safety risks. By virtue of their extensive training, professional engineers and 

properly credentialed individuals are uniquely suited to fill such a role. To become 

licensed or credentialed, these individuals must meet education, experience, and 

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NSPE Public Comments - Docket ID No. NIST-2021-0004

Aug. 19, 2021

examination requirements. Additionally, in most cases, these individuals must 

complete a continuing education requirement (the number of hours varies by 

state) to maintain their license or credential. By fulfilling a continuing education 

requirement, they stay abreast of new developments in artificial intelligence and 

its applications, and can use that knowledge to inform their role within an 

artificial intelligence risk management framework.

A credentialed individual, who is accountable for the safety of the public, will 

prioritize safety over profit or a rush to innovation.

NSPE greatly appreciates this opportunity to comment on NIST!s request for

input on an artificial intelligence risk management framework. Any further 

questions can be directed to Margaret Edwards, policy associate, at 

medwards@nspe.org.

 Sincerely,

Rick Guerra, P.E., F.NSPE

NSPE President