My concern is indirectly related to the new proposed regulations and as required by § 10.1-1408.2 of the Code of Virginia, a regulated medical waste management facility must have at least one operator licensed by the Board for Waste Management Facility Operators. To obtain the license, it requires passing a test which covers several hundred pages of regulations.  I have not received one justifiable reason for changing the test from open book, to closed book testing, after inquiring several times.  The ability to memorize several hundred pages of regulations and recall for a test does not seem to be a good demonstration of comprehension. Regulations were made to be referenced, and the test should be an indicator of one’s ability to locate and make applicable to a specific situation or question. The closed book test seems to intentionally eliminate candidates or potential operators, which in turn eliminates more jobs, greater impacting the small businesses within the proposed medical waste arena.

I appreciate the opportunity to express my thoughts on the matter.