Action | Amendment to the Board for Asbestos, Lead and Home Inspector Asbestos Licensing Regulations |
Stage | Proposed |
Comment Period | Ended on 4/14/2006 |
Specific comments on proposed regulations:
1. On page 27, section H. Standing, delete the words "as a" after the word "standing" in the first line.
2. Page 58, Item 12 This action against an "ostensible licensee", if I am interpreting it correctly, does not appear to make good legal or business sense. After all, you don't have to be a barber to own a barber shop. If I own an environmental company I am responsible for it's operation. What concern is it of the Board's if I hire competent "undisclosed persons" to manage it for me? If my business conscientously follows all the regulations and is profitable I am a happy owner and the Board should have no issues with me. Can the Board legally define who I can and can't hire? What kind of an "undisclosed person" could cause the licensee to be disciplined? How difficult would enforcement of this be?
3. Page 62, 18VAC15-20-456 Section A Recommend deleting "when the project monitor is present". Obviously inspections can't be done unless the monitor is present.
4. Page 62 18 VAC 15-20-456 Section B Recommend adding "for the entire time" to the first line following the word "day"