The Virginia Environmental Health Association represents environmental health professionals from the public sector, private sector, and academia in many areas of public/environmental health.  For the purpose of this forum, I wish to offer the following comments only with regard to the wastewater industry and these proposed regulations.

1 -   As a general opinion of the organization, requirements for licensure of all onsite professionals is a positive change.  It will create a "standard of practice" that will elevate recognition and acknowldegement of the profession and the role that we all play in protecting the health of the public and the environment.  

2 -  The organization would also like to offer support to the recommended changes proposed by OEHS to DPOR with regard to 18VAC160-20-96, specifically with regard to educational background/bachelor's degree for OSEs.

3 -  The organization is also an agreement with comments previously made by Michael Campbell of the Henrico Health Department on 2/12/09 specifically regarding interim licensure of experienced VDH onsite staff.