Subcontractor submitts an EOT Claim direct to the Engineer

1. The overall delay of the project is 95 days (including civil, architectural works, external works and MEP). The client is using FIDIC 1999.
2. Prior to MEP activities started the project was delayed by 13 days.
3. The major event occurred when the MEP contractor started chilled water piping 21 days later then the planned date.
4. The main contractor rejected the EOT claim submitted by the MEP contractor due to various valid reasons.
5. The EOT claim of the MEP contractor was based on the late approvals of the drawings and material submittals. Which was actually delayed by the large number (R0 to R15) of reviews of the drawings and material submittals.
6. The MEP contractor forwarded the same claim to the Engineer.
7. The Engineer suggested penalty of 82 days on the MEP contractor, considering 13 days delay by the main contractor while the MEP contractor was responsible for the rest of 82 days.
8. The Engineer also suggested a breach of contract penalty on the MEP contractor considering 7 activities were started late and pushed the contractual finish date by 82 days later then the contractual finish dated.

Can anyone tell me?

1. Can an on-board subcontractor forward or submit any claim directly to the Engineer or the Employer?
2. If the Engineer’s decision was right?
3. Did it happen anywhere before?

Cheers

Tanveer