Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
Previous Comment     Next Comment     Back to List of Comments
9/10/20  7:07 pm
Commenter: Robert William Crawshaw, AIA (Work Program Architects)

SUPPORT Continued Regulation of Interior Design in Virginia
 

My name is Robert and I live in Hampton, VA and work in Norfolk, VA. I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia.

Have lived in Hampton Roads since I was 6 years old; brought here through the US Navy. Save for one year of primary education, all of my schooling and secondary education has been in Virginia. I am an architect at Work Program Architects (WPA), a small 14-person architecture firm formed in 2011. Recently our team self-evaluated and realized our company needed a full-time certified interior designer; both to win work and to broaden our collective design skillset. As licensed architects, it was critical to our team that the interior design be certified to prove a commitment to the field. Ali has been able to step into our projects with a full understanding of accessibility, regional codes, and a mastery of understanding around both finishes and detailing. We have encouraged her to see herself as an equal in our firm even turning over project management on a couple projects. Our hope in hiring her was that our design work would become better by having a voice in the room that understood a greater consequence of the built form. In the midst of a global pandemic, she has offered us guidance on remote working environments for our own health as well as for the optic of the camera that our clients now see us. Her contribution is immeasurable and, in a short time, feels like a natural part of the process. In other firms, I have found interior designers striving to be part of the early design to the extent that we referred to their efforts as interior architecture; understanding the consequence of space wall beyond the finishes in a room. Being certified means you understand more that color coordination; in a small firm, it means you can be self-guided and thorough in design approach and application.
 
It is clear, eliminating regulation of Interior Design would gravely harm Virginia Certified Interior Designers, Interior Design small businesses, and others in the Commonwealth. For example:
– In order to hold a position on a corporate board for a “Professional Corporation,” the employee must be licensed or certified in their profession by the Commonwealth. Eliminating the interior design regulation would prevent interior designers from serving on the board of architectural-interior design and interior design-only firms.
– RFPs (Request for Proposals) and RFQs (Request for Qualifications) in the Commonwealth of Virginia and for Federal Government Projects that include Interior Design Services require that the Interior Designer providing these services be a Certified Interior Designer. Eliminating the regulation would bar Virginia interior designers from submitting for these proposals.
– Job postings for Interior Designers in the Commonwealth and for Federal departments typically require an Interior Designer to be a Certified Interior Designer. Eliminating the regulation would exclude Virginia interior designers from these opportunities.
 
In Virginia, of the 1,272 interior design establishments in the Commonwealth, 96% are small businesses of four or fewer employees. 83% of these small businesses are women or minority-owned. Eliminating interior design regulation would crush these entrepreneurs and small businesses because of the reasons listed in this comment.
 
Eliminating the Interior Design statute would also harm the Commonwealth. Being a Certified Interior Designer in the Commonwealth provides the public with knowledge that a minimum set of requirements, including education, experience, and testing, has been met. Certified Interior Designers do complex design drafting work in large public and code-regulated spaces like hotels, hospitals, corporate offices, and multifamily housing where public life-safety is implicated. CIDs have knowledge of building codes, standards, and other laws and regulations that are essential to the safe construction of public and other code-regulated buildings.
 
In light of the pandemic and as Virginians get back to their stores, businesses, and corporate offices, it is Certified Interior Designers who are redesigning and space planning these environments to mitigate COVID risk.
 
Our health is influenced by everything we touch in interior spaces. Disease-causing pathogens, like those that spread COVID-19, can be transferred from person to person, but also through everyday objects like office door handles, restroom grab bars, and schoolroom desks. It is critical to have interior environments that can protect our health by reducing pathogen transmission. Interior designers specify materials and finishes in 90% of residential and commercial construction and renovations and these professionals will be key in protecting the US against the virus.
 
Regulating interior design is a sensible practice. Washington D.C., Maryland, Georgia, Tennessee, and Kentucky, all have statutes in place for the regulation of the title and/or practice of Interior Design. In total, 27 states and two federal jurisdictions regulate interior design. No jurisdiction has ever deregulated the practice of interior design.
 
The interior design statute is not restrictive or protectionist. The title protection law—enacted during the 1990 Session of the General Assembly—does not restrict the scope of practice and serves as the framework for the voluntary certification program. While only certified interior designers may use the title “Certified,” any individual may contract with a client to render services as an interior designer, interior decorator, or similar practitioner if the client so chooses.
 
Eliminating the voluntary regulation of interior design in Virginia is bad public policy. Continued regulation is vital to the practice, profession, industry, consumers, and the public’s health, safety, and welfare. I ask you to not eliminate the regulation of this profession.
 
Thank you.
Robert

CommentID: 84747