As proposed, 18VAC 160-20-97C-3a inserts the term “authorized VDH employee”.  The proposed inclusion of the phrase "an authorized VDH employee" appears to be in conflict with the Code of Virginia, the Virginia Administrative Code and the AOSE regulations.

Since when was an "authorized VDH employee" anyone else other than a DPOR license holder?

The proposed text change in this section appears to be unnecessary and incorrect.  The random use of "an authorized VDH employee" becomes little more than another undefined term.  It is particularly misleading to assert that a VDH employee certifies any of these documents without a license. VDH inspection reports and completion statements must be signed by an appropriately licensed OSE or a licensed supervisory OSE overseeing the work of a non-licensed OSE or by a P.E. 

Recommend the Board delete the phrase "an authorized VDH employee" from this section.