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
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend Definitions of Supervision, SDS Experience and Document Requirements for Installers
Stage Fast-Track
Comment Period Ended on 11/7/2012
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11/4/12  8:28 pm
Commenter: Robert Savage, Affordable Septic Solutions, Inc.

Object to Fast Tracking
 

I would like to object to the use of Fast Tracking for these proposed regulatory changes, especially in regards to 18VAC 160-20-97C. (5) 3a which inserts the term “authorized VDH employee”.  Since the Onsite Soil Evaluator (OSE) is now a licensed profession regulated by DPOR with OSEs both working in the public sector for VDH as well as in the private sector it would seem that the term "authorized VDH employee" would conflict with the licensing regulations enforced by DPOR.  OSEs working for VDH should be held to the same strict licensing standards and requirements that OSEs are held to who work in the private sector.  I therefore request that these regulatory changes not be Fast Tracked but instead vetted through the normal legislative process with public review and comment. 

 

I also agree with the previous commentors who have also objected to Fast Tracking.

CommentID: 24436