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
Previous Comment     Next Comment     Back to List of Comments
2/22/17  1:45 am
Commenter: James Slusser

18VAC160-40-250. Qualifications for master conventional onsite soil evaluator licenses.

Item 2 and 3

While this appears to be an inherent bias by the Board, it does not serve the public interest.  Under the former VDH OSE program, such individuals were required to obtain six (6) years experience to meet entrance requirements.  To date, only VDH has complained about reducing entry requirements. 

WWWOOSSP Board should not be acting in any capacity to aid VDH in resolving job retention issues.  On it's face value, it appears the WWWOOSSP Board has a conflict of interest while reducing the experience time for the VDH onsite sewage system [training] program.  During the most of the drafting period of the proposed regulation, Mr. John Aulbach (VDH employee) was chair of the WWWOOSSP Board and under respectable circumstances, had a responsibility to recuse himself.  Failure to following such principles should be grounds for disqualification of the proposed regulation.


recommend Board to add six years experience to item 2 and item 3. 


CommentID: 57369