The seal is not about the draft
When a licensed professional engineer applies their seal to a document in Ontario, the seal carries a specific legal meaning under the Professional Engineers Act and Regulation 941. The seal attests that:
- The document was prepared by the engineer or under their direct supervision.
- The engineer has applied their professional judgment to the contents.
- The engineer accepts personal liability for the opinions, findings, and recommendations in the document.
The seal does not attest to who typed the first draft. It does not attest to the drafting method, the software used, or the number of revisions between first draft and final document. The seal covers the professional's judgment, not the production process.
This distinction has always existed. It predates AI. It predates word processors. A principal engineer who sealed a document drafted by a junior staff member in 1985 was not attesting that they personally wrote every sentence. They were attesting that they supervised the work, reviewed the document, exercised professional judgment over its contents, and accepted responsibility for the result.
The question of what "signed and sealed" means when AI wrote the first draft has a straightforward answer: it means the same thing it has always meant.
Three people who already write your first draft
In most Ontario structural engineering firms, the principal who signs and seals a field review report did not draft it personally. The first draft was produced by one of three people:
Junior engineers and EITs. An Engineer-in-Training accompanies the principal to site or conducts the visit under supervision, then drafts the report. The principal reviews, revises, and seals. The EIT's name may appear on the distribution list, but the seal belongs to the principal. The principal's review is the act that transforms a staff document into a sealed professional opinion.
External consultants and subconsultants. On large projects, field review responsibilities are sometimes shared with subconsultants who produce draft reports under the principal firm's supervision. The principal reviews the subconsultant's draft, applies their judgment, and seals the document. The subconsultant drafted. The principal attests.
Administrative staff. In some firms, an administrative coordinator transcribes the engineer's handwritten notes or voice recordings into the firm's Word template. The coordinator produces a draft. The engineer reviews, revises, and seals. The coordinator is not a licensed professional. The seal does not attach to the coordinator's work - it attaches to the engineer's review of that work.
In all three cases, the professional standard is the same: the person who seals the document is responsible for its contents. The drafter is an instrument of production. The signer is the professional. AI is a fourth drafter, not a first. The workflow is the same: produce a draft, review the draft, exercise professional judgment, sign and seal.
What changes and what doesn't
AI-assisted drafting does not change the legal meaning of the seal. But it does change two practical aspects of the workflow that principals should acknowledge.
The review becomes more important
When a junior engineer drafts a report, the principal's review catches two categories of errors: engineering errors (wrong finding classification, incorrect code citation) and drafting errors (unclear prose, missing context). The principal can generally trust that the junior's observations are accurate because the junior was physically present on site.
When an AI tool drafts a report, the principal's review has an additional dimension: the principal must verify that the AI's prose accurately reflects what happened on site. An AI tool can produce grammatically correct, professionally formatted text that mischaracterizes an observation, inverts a finding, or generates a plausible but incorrect code citation. The prose quality can mask a content error.
This means the review of an AI-drafted report should be more deliberate, not less, than the review of a junior-drafted report. The principal must read for content accuracy, not just for prose quality. Diff highlighting - showing what the AI generated versus what the engineer's notes contained - helps the principal verify that the content is faithful. But the responsibility for that verification rests with the principal, not the tool.
The drafting method becomes a quality assurance question
When a firm adopts AI-assisted drafting, the firm's quality assurance documentation should address the AI drafting step. Not because PEO requires it - as of this writing, no AI-specific QA requirement exists - but because a well-documented QA process is the firm's primary defence if the quality of a sealed report is ever questioned.
The QA documentation should state that the firm uses AI-assisted drafting, that all AI-generated output is reviewed by a licensed professional before sealing, and that the review process includes verification of observations, findings, code citations, and recommendations. If the firm's drafting tool produces an attestation record - a log showing who reviewed the draft, when, and what they acknowledged - the QA documentation should reference that log.
This documentation serves the same purpose as a firm's documentation of its peer review process, its template management, or its document control procedures. It demonstrates that the firm has a systematic approach to producing sealed documents, not an ad hoc one.
The parallel in medicine
The medical profession navigated the same question two years ahead of engineering and reached the same conclusion.
When Abridge and Ambience Healthcare introduced AI-generated clinical notes, the question was immediate: what does a physician's signature mean when AI wrote the note? The answer, consistent with the American Medical Association's augmented intelligence policy and the Federation of State Medical Boards' guidance on AI documentation, was that the physician's signature means the same thing it always meant - the physician reviewed the note, verified its accuracy, and takes responsibility for its clinical content.
The regulatory accommodation was straightforward because the medical profession already had a well-established concept of "the scribe" - a human who sits in the exam room, listens to the encounter, and produces a draft note for the physician to review and sign. AI scribes replaced human scribes. The physician's signing responsibility was unchanged.
Engineering has the same precedent. The EIT who drafts a field review report is the engineering equivalent of a medical scribe. The AI tool that drafts a field review report fills the same role. The principal's seal is the engineering equivalent of the physician's signature. The professional responsibility framework transfers cleanly because it was never about the drafter - it was always about the signer.
What your firm should document
If your firm uses or is evaluating AI-assisted drafting for sealed work, document three things before the question arises:
Your QA process for AI-assisted reports. State in your firm's quality assurance manual that AI-drafted reports undergo the same review process as any other draft. Specify who reviews (a licensed professional), what they review (observations, findings, citations, recommendations, photo captions), and how the review is recorded (attestation log, revision notes, or other documentation).
Your data handling policy. State that client project data - site photographs, observation notes, sealed report content - is not shared with AI model training. This is a contractual matter with your AI tool vendor, but documenting it in your QA manual demonstrates that the firm has considered the confidentiality implications.
Your position on the seal. State that your firm's position is that the seal attests to the professional's supervision and judgment, consistent with Regulation 941, and that the use of AI-assisted drafting does not change the meaning or weight of the seal. This statement may seem obvious, but having it in writing means the answer is ready when a client, a code authority, or PEO asks the question.
These three documents take an hour to prepare. They will not change how your firm produces sealed reports. But they will demonstrate that your firm approached AI-assisted drafting with the same rigour it applies to every other aspect of its professional practice - which is exactly what "signed and sealed" has always meant.