As stated numerous times by previous objectors, please accept my objection to the fast track process. The definition changes appear to be vague in nature and may lead to further confusion by our regulant community. As stated in the proposed regulations; "Direct supervisor" means a licensed operator, installer, or evaluator who undertakes the supervision of an unlicensed individual engaged in activities requiring a license for the purpose of obtaining the competence necessary to qualify for licensure and who. The direct supervisor shall be responsible for the unlicensed individual's full compliance with this chapter. The direct supervisor within the VDH/OSE community in many cases is the same person who will provide a regulatory approval. Inadvertently, this will create a conflict of interest.

18VAC 160-20-97 C-3a

The term "authorized VDH employee" appears to be vague and subject to scrutiny. Please define what an "authorized VDH employee" consists of.

18VAC 160-20-97 C-3b

AOSE/professional engineer inspection report and completion statements shall be certified by either an authorized onsite soil evaluator or a Virginia licensed professional engineer;--please define what "certified" or what tasks must be completed in order to "certify". Furthermore, the term "AOSE" appears to be irrelevant in the context used within this section. Only systems installed in the past 36 months may be used for experience credit. The "Authorized Onsite Soil Evaluator (AOSE) expired on June 30, 2009, which exceeds the three (3) year time window.

Thank you for allowing me to express these concerns in writing for your consideration

Earnestly,

 James B Slusser, AOSE 1072