I object to the Regulations as drafted, and advocate WWWOOSSP reconvene to establish a regulated professional seal conforming to the requirements in code and historical practice, and as advocated through VAPSS comments entered into the NOIRA.

An OSE works under exemption through PE board (54.1-402); one of the requirements of licensure requires sealing documents under control of professional. To wit:

18 VAC 10-20-760.B.4 The seal of each regulant responsible for each profession shall be used and shall be on the originals, including the document cover sheet, for which that professional is responsible, including exempted work, for which licensure or certification is not required, prepared under the regulant's direction.

The OSE is the only design professional in the Commonwealth unable to provide substantive assurances through sealing. The seal provides the public visible reliability for purposes of commerce and trade.  Among the substantial reasons to require sealing of professional design documents we recognize confirmation of: authenticity, responsibility & attestation.