Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Waste Management Facility Operators
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4/8/24  1:29 pm
Commenter: James Canty

Open/Closed-Book Exam

Please consider the negative impacts of a closed-book testing platform. The exam was administered successfully as open-book for years, and many current licensees who tested this way are effectively performing their duties.  Forcing memorization of text materials to pass the test is potentially counterproductive if the ability to efficiently utilize the resource documents is lost in the process.  The logic of training licensees to pick up the reference book and proficiently access the broad range of data therein at any given point in time throughout their career is a higher skillset than temporarily reproducing data for a test and then likely failing to retain much of it. As regulations and industry standards are in a constant state of evolutionary development, the skill of knowing which source document applies and how to search its contents to solve problems and perform safe, efficient, and compliant operations is the higher goal of any related proficiency testing.  Negative impacts on workforce recruitment and long-term career advancement need to be factored into the consideration of the testing platform.  The prospect of a closed-book testing platform may well yield the unintended consequence of deterring generally capable and willing professionals away from a tenured career in solid waste management if their learning style is not congruent with memorization of this volume of data, yet with proper training in the use of regulatory and operational manuals, they could be successful in their roles and demonstrate this skill through their licensure testing and continuing education.  In a world where many entering or navigating the workforce have been encouraged to seek work in computer information technology or other generally non-manual industries, significant focus should be applied to the ability to attract, recruit, train, and advance individuals with the fortitude and commitment to enter the solid waste industry. Providing a reasonable path to licensure is essential to the long-term sustainability of the industry, and returning to the open-book testing model keeps these opportunities more accessible to a broader population. 

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