The human health and the environment of the Commonwealth must be protected by requirements of rigorous qualification and accountability of the professionals that work to protect the public and provide them services. Any action or exemption that lessens the training or experience requirements for practice should be removed from proposed changes to existing regulations. In fact, requirements should be maintained and strengthened to protect the professions involved and the public in the long-term scope. We have licensed professional soil scientists and certified professional soil scientists in Virginia. They can do the jobs required by the public and have invested in creating a profession that requires training and experience at acceptable levels to serve and protect the public and the natural resources of the Commonwealth.

Furthermore, it is my opinion that the role of the VA DOH-EHS should be strictly regulatory, and not engaged in any form of design services. The proposed change in the regulations not only makes it easier for the DOH-EHS to engage in design services, but facilitates the DOH's role in what should be a practice of the private sector, exclusively.