Agencies | Governor
Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
Onsite Sewage System Professionals Licensing Regulations [18 VAC 160 ‑ 40]
Action General Review 2014
Stage Final
Comment Period Ends 2/22/2017
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2/22/17  12:34 am
Commenter: James Slusser

18VAC160-40-240. Qualifications for journeyman conventional onsite soil evaluator licenses.

18VAC160-40-240. Qualifications for journeyman conventional onsite soil evaluator licenses.
An applicant for licensure as a journeyman conventional onsite soil evaluator shall furnish acceptable
documentation that one of the following has been met:

The WWWOOSSP Board has no public purpose or statutory function to create a new subclass of licensure for onsite soil evaluators.  Confusion exists between the labor market of tradesmen and those persons offering professional services; I would like to elaborate on the latter.  Persons seeking licensure as a professional engineer or surveyor apply for an apprenticeship which lasts at least four years under the direct supervision of a licensed professional prior to taking the established entrance exam.  While under the direct supervision of  a licensed person, qualified persons are challenged with increasing assignments.  After the four years of practical experience and passing a state sponsored exam, those individuals are free to practice under their own license.

WWWOOSSP Board elected to abandon the existing practice on September 27, 2011 at the request of Virginia Department of Health (VDH) Director, Mr. Allen Knapp.  The Board reported Mr. Knapp as stating,

The Board's interpretation that the licensed employee be present and directly supervise all work performed by the unlicensed employee has added VDH travel costs and will require additional staff to be hired and trained.

Restructuring the onsite model for VDH was a peculiar benefit that not only impacts the public, but industry as well.  Altering the professional pathways created a vicious cycle where VDH continued to recruit and hire unlicensed persons.  After the law was changed in 2009, why was VDH allowed to persist by hiring unlicensed persons?  There is no other industry that requires a license which will allow ANY entity to hire those unlicensed.

Please find every profession or trade that requires a license prior to practicing.

Performing ministerial duties of state does not require a license.  Participating in a regulated profession does require a license.  Prior to  dismissing my concerns, would the WWWOOSSP Board please explain to the existing license class and public why programmatic changes were made for an agency that is meddling in commerce? 





CommentID: 57362