Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
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9/29/20  2:12 pm
Commenter: Rosemary G Gray,NAVFAC

https://townhall.virginia.gov/L/entercomment.cfm?generalnoticeid=1150.
 

My name is Rosemary G Gray and I live and work in Virginia.  I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia. I have worked for Architectural firms, owned by own business, worked for facilites departments and now for the Navy. All have depended on my knowledge that was gained by going to an accredited university, passing the NCIDQ exam and getting the VA certifications.
 More and More people are watching the TV shows that have quick interior design renovations done before the show ends. That is what most people think a professional interior designer does. Wake up and realize that it is not!! We don't fluff pillows and pick colors.  I have been a professional Interior designer in Virginia for 40 years and I am still looked upon as a color picker or an "Interior Decorator".  The Virginia Certification has separated the uneducated designers from the Professional qualified designers. Most Professional interior designers have gone to a university that has been accredited by the Council for Interior Design Accreditation (CIDA) . This council has a Standards Committee  which performs regular reviews to monitor relevant issues and determine areas or items for immediate revision to current standards. This timetable recognizes the continuous development of the practice of interior design, the expanding body of knowledge in interior design, and changes in post-secondary education. The Council for Interior Design Accreditation (CIDA) continuously monitors the validity and reliability of standards. This research informs the standards development process. As changes in the profession or higher education warrant, comprehensive research into the field of interior design and education is conducted to determine appropriate revisions to all standards. They insure that a graduate in Interior Design has the knowledge that encompass all spaces within environments built for human habitation.  A creative professional can identify and analyze problems from many different perspectives and synthesize information. Here are a  few of the subjects that a professional interior designer must be proficient with: Global Context, Collaboration, Business Practices and Professionalism, Human-Centered Design, Design Process, Communication, History, Design Elements and Principles, Light and Color, Products and Materials, Environmental Systems and Human Wellbeing, Construction, Regulations and Guidelines.

Don't you want to make sure when you need an Interior Designer they have all the qualification that are listed above? The continued regulation and certification process in Virginia does this. We need to keep this in place. If anything make it harder to get a certification instead of taking it away.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.

Rosemary Gray CID

CommentID: 86930