The tradesman continuing education requirement is not an unnecessary or burdensome regulation as stated by the Board under the NOIRA section titled “Need”. Board comments under this section imply that tradesman regulations without the continuing education requirement “effectively protect the health, safety, and welfare of the public”. I disagree with this statement and I'm not aware of any other tradesman regulation that requires licensed tradesmen to keep up with recent Code revisions or to improve their trade knowledge. As you know, Code revisions are brought about to prevent damage to property and to protect life safety; these objectives are accomplished by bringing together the accumulated knowledge of Building Officials, trade organizations, manufacturers and other stakeholders to eliminate hazards. Continuing education on recent Code revisions is important to help tradesmen recognize these definable hazards, because it is impossible to avoid a hazard that you are not able to recognize or understand.

The Board makes a statement under the NOIRA “Alternatives” section that “No viable alternative has been identified”. One possible alternative that the Board may have failed to consider would be making continuing education a requirement to be met sometime during the three year Code revision cycle instead of once during the two year license renewal cycle. Obviously, the existing requirement for continuing education on a two year interval results in repeating continuing education on the same Code changes due to its three year revision cycle. Changing license renewal and continuing education requirements from two year to a three year interval would reduce costs and ensure that tradesmen will regularly receive information on Code revisions.

It is apparent that the Board understands the value of continuing education as evident by the fact that electrical tradesmen are not part of this proposed regulatory action. I have difficulty understanding why the HVAC, plumbing and fuel gas trades are considered any less hazardous to life and property than electrical trade work. If electricians should have to meet continuing education requirements, why are the other trades considered less important or less of a hazard to public safety? 

The Board of Contractors has a basic obligation to protect the general welfare of Virginia citizens. Elimination of continuing education requirements for all but the electrical tradesmen goes against the Board's obligation and will result in less protection for consumers of HVAC, plumbing and fuel gas trade related work.

Respectfully submitted,

Edwin Ward, P.E.

VA Professional Engineer #0402018319

Master ELE, HVA, PLB & GFC Tradesman #2710006725