Virginia Regulatory Town Hall
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Board for Professional and Occupational Regulation
 
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9/20/20  10:48 am
Commenter: Tom W Ashton

SUPPORT Continued Licensure of Soil Scientists
 

SUPPORT Continued Licensure of Soil Scientists

 

The observations and characterization of the benefits that the Licensed Professional Soil Scientist (LPSS) provide to the citizens of the Commonwealth, and the extent of which soil science integrates with and supports many disciplines, have been comprehensively outlined by others in their comments.  

 

I have been active as an On-Site Wastewater “Soil Consultant” in Virginia from 1987 to date.  My CPSS was integral in my securing my current position in 1993 with a Virginia based national company providing products and soils / engineering services to the On-Site Sewage industry.

 

In my experience and observations in other states, those states that do not have recognition and affirmation (by occupational regulation) of a soil’s professional are lacking in the proper application of regulatory programs.  My current Virginia LPSS credential adds to my credibility in the performance of my profession and the growth of our business.

 

In the case of many regulatory programs, particularly On-Site systems, prescriptive requirements are essentially guidelines that in many cases do not address critical conditions that otherwise would be identified by the practicing professional.

 

Since the late 1970’s this need was identified by the Virginia Association of Professional Soil Scientists (VAPSS), recognizing that the Professional Soil Scientist protects the public welfare.   The result was DEPOR Certification and later Licensure, with VAPSS encouraging all qualified soil scientists to obtain the credential.

 

As is typical of similar routine program reviews and summary’s, the JLARC report identifies that there are other disciplines that can provide the same services to the public as the LPSS.

 

In the case of the Virginia Department of Health (VDH) individual on-site sewage disposal system program, a majority of the services to the public are privatized with private sector providing on-site system evaluation and design.  These services are required provided by a DEPOR licensed On- Site Evaluator (OSE).  This license is specific to the prescriptive regulation involving general criteria, forms, and procedures as minimally necessary to administer the program. 

 

Many Soil Scientists have obtained the OSE license out of necessity to continue their practice.  In the infancy (1990’s) of the OSE concept, administered by VDH, the Certified Professional Soil Scientist (CPSS) was the sole criteria to become an “Authorized” OSE. 

 

By definition an onsite “Treatment Works” includes the soil as an important element of the system design recognizing in function it’s importance as a compliance point of which effluent is discharged into the environment. 

 

Many Professional Engineers (PE) who practice in On-site Sewage System design value the LPSS site characterizations, descriptions, and interpretations of the soil absorption area. 

 

The site reports of a LPSS are particularly important in the case of system design with soil conditions not meeting the prescriptive requirements of the regulations requiring utilization of the “Practice of Engineering” in these performance system designs.

 

Larger system designs, requiring PE certification, such as those address community infrastructure and rural commercial development (including wineries / breweries) necessitate a level of evaluation and interpretation that the LPSS provides.       

 

In 2011, the General Assembly unanimously voted to require licensure for soil scientists due to risks associated with lack of regulation. 

 

Licensed soil scientists are highly skilled in their field as a result of educational background, years of field experience, continuous study and coursework, and participation in professional organizations. A licensed soil scientist has taken a state exam and must maintain continuing education to maintain the license.

 

Maintaining the license qualifies the professional soil scientist for automatic certification as an ESC plan reviewer under the Department of Environmental Quality (DEQ) Erosion and Sediment Control criteria and satisfies the requirements for Erosion and Sediment Control and Storm Water re-certifications through DEQ. 

 

The CPSS and now the LPSS has always been a valued credential in VDH employment.  The VDH central Office of Technical Services has a senior team LPSS position.

 

Virginia Polytechnical Institute and State University (VPI & SU) provide curriculum for and awarding degrees in Soil Science.

 

As licensees, clients- including state and federal agencies, know the persons being hired for a project are fully trained and tested in the field of soil science with expectations that the product of our work will meet the standards of other licensed professionals and protect the health, welfare, and environment of the Commonwealth of Virginia. 

 

I have operated a small soil consulting business for over 30 years in Virginia which is directly affected by the soil scientist licensure program. If the licensure is eliminated, my business will be economically impacted. I feel very strongly that the soil scientist licensure program should be maintained. 

 

Thank-you

 

Tom W. Ashton

 

Licensed Professional Soil Scientist (CPSS 1991 to LPSS 2013, DEPOR)

Licensed Master Alternative Onsite Soil Evaluator (VDH AOSE to DEPOR 2009)

Registered Environmental Health Specialist (R.E.H.S., N.E.H.A., 1985)

 

 

 

 

CommentID: 85147