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 2014
Stage Proposed
Comment Period Ended on 2/12/2016
spacer
Previous Comment     Next Comment     Back to List of Comments
2/9/16  7:26 pm
Commenter: bob marshall / cloverleaf env. cnslt., inc.

18VAC160-40-10. Definitions.VDH, Inc.
 

Definitions.VDH, Inc.

The fact that a state agency (VDH) is in direct competition with private business over which it has regulatory review authority and has the power to set up the process to favor themselves should be alarming to every citizen.   

Suggested amendment to the proposed definition change.  As of July 1, 2009, VDH embodies so much more than just the Virginia Department of Health. VDH is now a statewide franchise operating with impunity as a business entity across the Commonwealth.  Embrace merging state and corporate power with a marketable definition that better reflects the VDH regulatory body operating as a business, to protect the public health, safety, and welfare of Virginia citizens.  Disclose to the public the entrepreneurial benefit of unresolved conflict of interest and unsupervised monopolization of this profession by VDH, the largest employer of licensed regulants under the Board's purview, per Code of Virginia § 54.1-100 - Regulations of professions and occupations:

No regulation of a profession or occupation shall conflict with the Constitution of the United States, the Constitution of Virginia, the laws ofthe United States, or the laws of the Commonwealth of Virginia.

Suggest the proposed language be amended under 18VAC160-40-10, as follows:

18VAC160-40-10. Definitions.

B. The following words, terms, and phrases when used in this chapter shall have the following meaning unless the context clearly indicates otherwise:

"VDH" means the Virginia Department of Health, Incorporated.

CommentID: 49527