Route 2: observation and parallel documents
This is the provision most Interns have never read, and it is written directly into the IAP manual. The manual acknowledges that an Intern may not always be able to complete some areas of experience directly, and that for certain activities they may instead participate as an observer. It gives a concrete example: it may be impractical for an Intern to represent the office at a site meeting and write the follow-up report, but practical for them to accompany the qualified person often enough to know what is expected, and then prepare a follow-up report for the Supervising Architect's review.
That second document, the one you prepare in parallel with the one that gets issued, is what the manual calls a parallel document. You did not sign it and it did not go to the contractor, but you produced it, an architect reviewed it, and it evidences the competence the category is testing for.
So yes: you do not always have to be the one who performs the work. But this route comes with conditions that decide whether the hours count, and they are easy to miss.
Read this before you log a single observation hour
Your Supervising Architect must disclose it. The manual requires the Supervising Architect to indicate in their CERB comments to the ROAC jurisdiction where observation or parallel documents were used. This is not optional, and it means your entries and their comments have to agree.
It is discretionary, not automatic. The manual states that credit for experience as an observer or by completing parallel documents may be granted by the ROAC jurisdiction only under exceptional circumstances, and directs Interns to contact the jurisdiction for clarification. Treat it as a route you apply for, not one you assume.
Verification is your responsibility. The manual is explicit that it falls to the Intern to confirm with their ROAC jurisdiction whether observation or parallel documents will be accepted. Ask in writing, before the hours accumulate, and keep the reply.
What a jurisdiction actually asks for: Ontario as the worked example
The national manual sets the principle. Your province sets the mechanics, and they are far more specific than the manual suggests. The OAA publishes its rules in OAA Appendix B, Ontario-Specific Requirements 2026, which devotes an entire section to observer and parallel documents experience. If you are enrolled elsewhere, your regulator publishes its own Appendix B and the details will differ, but Ontario shows the shape of what to expect.
The most important rule in it is the one that costs people the most: pre-approval is required, and experience gained before pre-approval is not accepted. There is no retroactive credit. An Intern who spends eight months quietly accumulating observation hours and then asks whether they count has already lost them.
Ontario treats two situations separately.
- Observation inside your place of employment requires OAA pre-approval. The submission sets out the proposed project, which CERB experience categories the hours will land in, how the specific activities will actually be acquired, the hours expected per category and activity, and the name of the supervising Architect. A form goes with it.
- Observation outside your place of employment requires pre-approval as well, plus confirmation from your Supervising Architect that the activity genuinely cannot be obtained where you work. It also carries a separate CERB submission with comments from both the supervising Architect and your Mentor, and a cumulative cap of 600 hours.
Now the detail that matters most for this post. Ontario excludes seven experience areas from observation and parallel documents entirely: Schematic Design, Engineering Systems Integration, Code Research, Design Development, Construction Documents, Document Checking and Co-ordination, and Energy Literacy/Sustainability.
Every one of those sits in Category A. None of the three Construction Administration areas appears on that list. In other words, the route is closed for most of the design and documentation work and open, subject to pre-approval, for exactly the category that Interns most often cannot reach. That is not an accident. It is a recognition that Category B depends on having a project in construction, and that many Interns do not.
Two cautions come attached. The OAA states plainly that it expects most hours to be gained through direct experience, with observation supplementing rather than replacing it. And an assessment interview with the Experience Requirements Committee may follow if observer or parallel experience shows deficiencies or raises competency concerns. This is a supported route, not a soft one.
How to use the route well
- Get pre-approval before the first hour, not after the last. In Ontario this is mandatory and non-retroactive, and other jurisdictions apply their own version of it. One email to your provincial association describing your situation and asking what they will accept, and in what proportion, is worth more than a year of assumptions.
- Attend often enough to be useful, not occasionally. The manual's own framing is accompanying the qualified person often enough to know what would be expected. One site visit is a tour. A standing weekly attendance builds the judgment the area is testing.
- Produce a document every time. Draft the field report, the meeting record, the payment recommendation, the deficiency list. Then get it reviewed. Observation without a work product is very difficult to assess and very easy to reject.
- Do not dress observation up as participation. Since your Supervising Architect has to flag the observation in their comments, an entry that overstates your role contradicts your own file. Describe what you produced and let the record be accurate.
- Use it to supplement, not to replace. The strongest files pair genuine assigned work with observation where assignment was impossible. This is not just good practice, it is the stated expectation: a file made mostly of observation hours invites the exceptional-circumstances test in its harshest form, and in Ontario it can trigger a committee assessment.