Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Onsite Sewage System Professionals Licensing Regulations [18 VAC 160 ‑ 40]
Action General Review 2014
Stage Proposed
Comment Period Ended on 2/12/2016
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2/9/16  9:39 pm
Commenter: bob marshall / cloverleaf env. cnslt., inc.

18VAC160-40-10. Definitions.Journeyman
 

Definitions.Journeyman

Very strongly object to the proposed definition.  After Mr. Allen Knapp disclosed market participation during the OSE/PE Workgroup April 2013, that VDH wouild be leaving the business, why is the Board proposing to irreversibly amend these regulations to accomadate VDH with a journeyman definition?  Did the Board consider or do they care – how the people of Virginia might be harmed by their decisions?  Journeyman, as written, is a manufactured category for an untrained and unexamined employee, under contract, not required to seek licensure.  Is the Board unwilling to recognize the cardinal requirement to license regulants by examination, education, and experience or the cardinal benefit to protect consumers?  After significantly discounting qualifications for obtaining licensure in this text, does the Board fully appreciate the unintended consequences of scapegoating the least qualified and poorly trained entrant to the profession.

Suggest the proposed language be removed under 18VAC160-40-10, as follows:

18VAC160-40-10. Definitions.

B. The following words, terms, and phrases when used in this chapter shall have the following meaning unless the context clearly indicates otherwise:

"Journeyman" means an individual who possesses the minimum skills and competency to assist with the installation or maintenance of onsite sewage systems or assist in the evaluation of soil sites as suitable for conventional and alternative onsite sewage systems and to design conventional onsite sewage systems under the direct supervision of a master licensee.

CommentID: 49532