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
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend regulations to license onsite sewage system professionals.
Stage Proposed
Comment Period Ended on 3/6/2009
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1/16/09  11:03 am
Commenter: David B. Beahm, President, Central Virginia Soil Consulting, Inc.

Create Board for Licensed Professional Soil Scientists
 
I have been a Virginia Certified Professional Soil Scientist since 1992 (No. 3401000077) through examination (no grandfathering).  When I attended Virginia Tech, I chose to pursue a degree in soil and geological science with the desire to become a professional soil scientist just as any individual wanting to become an engineer would pursue and engineering degree.  After my four years of documented experience as a soil scientist I qualified to take the exam, which I studied for quite intensely.  When I took the exam, I found it to be very thorough and challenging, which is a credit to The Board members for being very diligent to ensure that all knowledge in the discipline of soil science is evaluated. 
 
I have been conducting soil/site characterizations for on-site sewage systems since graduating college in 1988.  The knowledge that I obtained through my education as a soil scientist gave me the basic requirements for completing a full and thorough evaluation of sites by holistically applying the principles of soil, geologic and hydrologic sciences.  It cannot be overemphasized that without a fundamental knowledge in the aforementioned sciences, and with adequate experience, no site should ever be evaluated by any individual without proven credentials.   Its all a matter of protecting public health and the environment. 
 
Since 1995, the state of North Carolina has had a Board for the Licensing of Soil Scientists.  (Please see website www.ncblss.org/hbill826.html.)  Under North Carolina's licensing for soil scientists, the definition of the practice of soil science is as follows;

(4) `Practice of soil science' means any service or work, the adequate performance of which requires education in the physical, chemical, and biological sciences, as well as soil science; training and experience in the application of special knowledge of these sciences to the use and management of soils by accepted principles and methods; and investigation, evaluation, and consultation; and in which the performance is related to the public welfare by safeguarding life,health, property, and the environment. `Practice of soil science' includes, but is not limited to, investigating and evaluating the interaction between water, soil, nutrients, plants, and other livingorganisms that are used to prepare soil scientists' reports for: subsurface ground absorption systems, including infiltration galleries; land application of residuals such as sludge, septage, and other wastes; spray irrigation of wastewater; soil remediation at conventional rates; land application of agricultural products; processing residues, bioremediation, and volatilization; soil erodibility and sedimentation; and identification of hydric soil and redoximorphic features.

 
I invite you to review the North Carolina licensing of professional soil scientists regulations as I feel that the state of Virginia should adopt a very similar course of action.  Anything less would be very substandard. 
 
I am a member of VAPSS and VOWRA; however, I am sending you this e-mail on my own accord.  I do, however, understand that VAPSS is uniformly seeking to adopt the licensing of soil scientists in Virginia. 
 
Please recall the history of when the Virginia Department of Health adopted the AOSE program.  When the AOSE program was initially set up, all CPSS's were called upon to become AOSE's under the emergency guidelines. 
 
Under the current health department AOSE program, only a very abbreviated knowledge of soil science is required.  As a professional soil scientist who went through four years of college and passed the CPSS exam, I must admit that it is professionally insulting to me that the health department allowed such inadequacy in their required knowledge of soil science to become an AOSE!  This should not be allowed to continue.
 
In conclusion, my request to you is as follows;
 
  1. Convert the Board for Certified Professional Soil Scientist to the Board for Licensed Professional Soil Scientists
  2. All existing CPSS's should be grandfathered as Licensed Professional Soil Scientists
The state of Virginia now has the opportunity to make some very important changes in how on-site wastewater treatment and disposal sites are evaluated.  Its all a matter of the protection of public health and the environment as well as minimizing economic impact to property.  We need to ensure that the highest standard of professionalism is sought by all those in charge of making the decisions regarding who and how sites are evaluated.  Neighboring states have acknowledged the importance of thorough knowledge of soil science for performing any subsurface evaluation and have put in place the mechanism that ensures that anyone doing so has the proven knowledge and experience.  I think that it would be a great embarrassment to the Commonwealth of Virginia if any less of a requirement is adopted. 
 
 
Thank you for your thoughtful consideration in this matter.
 
David B. Beahm, President
Central Virginia Soil Consulting, Inc.
12719-D E. Lynchburg-Salem Tnpk.
Forest, Virginia 24551
 
434-832-0464
 
CommentID: 6705