Commenter: James Slusser *

18VAC160-40-270 Qualifications for master alternative onsite soil evaluator licenses (Item 1)

qualifying experience..... strike THREE and enter SIX

Two years of practical experience is insufficient to prepare site plans and construction specifications.  WWWOOSSP Board decision to reduce qualifying experience is arbitrary at best and lacks any fundamental merit.  Correlation may not be causation, but there is an awkward relationship between VDH  employee attrition  rates and reducing applicant qualifications seeking licensure.  Please consider Board comments on a past VDH concern.

Commenter: Jack Watts, AOSE *
18VAC160-20-96.B.1. Qualifications for licensure – onsite soil evaluators

Recommend adding another option.

e. Two years of full time experience evaluating site and soil conditions in compliance with this chapter under the direct supervision of a licensed conventional onsite soil evaluator or of a licensed alternative onsite soil evaluator, and a graduate of the VDH onsite sewage system training program.

VDH has been a trainer for Authorized Onsite Soil Evaluators for years.  

As taken from the Virginia Department of Health AOSE Regulations:

DPOR RESPONSE FROM FINAL REGULATION AGENCY TOWN HALL DOCUMENT dated March 31, 2009:

...In addition, the Board has amended the language to allow certain VDH personnel to obtain an interim onsite soil evaluator license that will be valid only for their work as an employee of VDH.

Virginia Department of Health  27 of 54
Authorized Onsite Soil Evaluator Regulations

3. A person who demonstrates to the satisfaction of the division that he has at least six
years of full-time experience evaluating site and soil conditions for onsite sewage
systems in Virginia in accordance with the Board of Health’s regulations (12 VAC 5-
610-20 et seq.) and a two- or four- year college degree shall be eligible to receive a
certificate as an AOSE provided:
a. The applicant successfully completes a training course or courses designated
and approved by the division;
b. The applicant passes the AOSE written and field tests; and
c. The applicant provides a written statement signed by a current or former
supervisor or an AOSE with a current certification stating that the person is sufficiently experienced to become an AOSE.

The WWWOOSSP Board has failed to recognize the differences of education and experience to become a VDH employee (sanitarian) and a licensed onsite soil evaluator.  To date, approximately 25 percent of VDH staff can not produce a- to scale site plan.  While the agency exempts certain sanitarian skills for VDH employment, the license skills are necessary to protect public health, safety, and welfare while providing designs to make improvements to real property.

Reducing professional entry standards provides no benefit to the consumer or industry entrepreneurs seeking a qualified labor force.

Please revise the entry standard to six years of qualifying experience for persons under this category.