Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Onsite Sewage System Professionals Licensing Regulations [18 VAC 160 ‑ 40]
Action General Review of Onsite Sewage System Professionals Licensing Regulations
Stage Proposed
Comment Period Ended on 7/18/2025
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Previous Comment     Back to List of Comments
7/17/25  8:42 am
Commenter: Stuart M. (Mike) Lynn

Supervision
 

Working across the state as a representative on the Sewage Handling Advisory Committee and as a Board member for VOWRA, I hear a consistent theme related to a lack of licensing enforcement by VDH and lack of understanding the supervision requirements of journeyman and unlicensed workers by Master or journeyman licensed individuals.  Why does VDH accept and approve the construction work of unlicensed or improperly licensed individuals and contractors? Some with no contractor's license at all.  Why does VDH accept pump out reports into their electronic database for conventional or alternative systems from unlicensed or improperly licensed operators?   Will DPOR please more specifically define in regulation or guidance if an unlicensed worker performing regulated soil evaluation, operation, maintenance or installation must have a journeyman or master licensed individual onsite at all times work is ongoing.  I can see a difference in longer term projects where a master or journeyman might be able to supervise several jobs with laborers working by checking on them frequently during the project and especially before covering up completed work.  Compared to a pump out, Routine O&M inspection or minor maintenance such as a float or plump replacement that may take a total time on the job of 1 to 2 hours.  Many septic and alternative tanks are being pumped by unlicensed workers where one master licensed individual in the entire company is supervising 3 - 6 trucks on the road.  If this is what DPOR intended then say so, if not we have a lot of training and licensing to do that wont begin until there is clear definition.  Also, lots of work on alternative systems with conventional licensed companies.      

CommentID: 236966