EXHIBIT F

"Practitioner Comment:   Need to enforce or regulate or make VDH Environmental Health Specialists permit submissions conform to what VDH requires of Private Sector permit submissions." --K.R. DAVIS

..."The Board regulates individual licensees, who need to comply with VDH and DEQ regulations...In the current regulations, at least one person in the practitioner’s office or company MUST have the appropriate license and act as the “Supervisor” or “Responsible Individual in Charge” of all non-licensed staff..." [emphasis added] --K.R DAVIS

"In an effort to address this situation, the Board has proposed in the regulations to created a “Journeyman” license” category that would require ALL individuals working in the Onsite Industry to be in possession of some type of  license... This should have the effective of bringing all VDH EHS staff under the purview of the Board.  There is a minimum amount of continuing education required, but no test is required to obtain a Journeyman license." [emphasis added] --K.R. DAVIS

On September 27, 2011  a motion was made as stated,
"Mr. K. Davis moved that if a licensed onsite soil evaluator has a direct employer-employee relationship or a written contract with an unlicensed individual, the unlicensed individual may perform soil evaluation tasks without the licensed onsite soil evaluator being present.  The licensed onsite soil evaluator will be responsible for the unlicensed individual's compliance with all applicable laws and regulations...."[emphasis added] see board minutes      http://townhall.virginia.gov/L/GetFile.cfm?File=C:\TownHall\docroot\Meeting\17\15657\Minutes_DPOR_15657_v2.pdf

Comment:  Does the WWWOOSP Board concede that the existing policy and regulations failed to provide adequate regulatory oversight?