Agencies | Governor
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 Final
Comment Period Ends 2/22/2017
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2/22/17  4:31 pm
Commenter: James Slusser

18VAC160-40-270. Qualifications for master alternative onsite soil evaluator licenses (ITEM 4)
 

 18VAC160-40-270. Qualifications for master alternative onsite soil evaluator licenses

Propose the board strike four years and replace with eight (8)

Four ] Eight years of full-time experience evaluating site and soil conditions and designing alternative onsite sewage systems verified by one or more of the following: an authorized onsite soil evaluator [ certified by VDH before July 1, 2009 ], a professional engineer, or an alternative onsite soil evaluator.

From the former VDH AOSE program,

A person who demonstrates to the satisfaction of the division that he has at least eight years of 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.) 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 successfully completes the AOSE written and field tests approved by the division, 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

During review of the Onsite Sewage Disposal System Research in Florida, an Evaluation of Current OSDS Practices in Florida, March 1993 (below), industry concerns were listed as how to improve on lot wastewater treatment.

In the 1950's, states began to promulgate improved codes with the intent to provide a rational basis for the design and installation of septic tank systems.  The codes, which were enforced by local public health departments, were centered around the "percolation test", and local practices and experiences. Codes were not based on scientific principles, but on empirical relationships and folklore.  They were based on several incorrect assumptions:
• The design of systems could be based on a clean water percolation test which ignored the complex interrelationships between soil characteristics and conditions, character of the wastewater, biological mechanisms, and climate,
• A prescribed design could be used for all sites meeting certain minimum requirements,
• Siting, design, and construction could be performed by untrained persons,  
• Operation and maintenance of the system could be performed by an uninformed owner,
• Compliance with public health objectives would meet environmental protection requirements, and
• Onsite wastewater systems would be only a temporary stage toward progressive development of central sewerage and, therefore, provisions to proactively manage the systems or to deal with failures when sewers were not available would not be necessary.
Largely because of these flawed assumptions, the success of early codes in regulating system use and preventing system failure has been limited.  Subsequent efforts to improve codes have been done largely by revising existing codes.  As a result, many of these basic assumptions have been implicitly perpetuated.  Much of the reason for this is that the regulation of onsite wastewater systems has occurred within the public health sector by people that have had little training in wastewater engineering.  While these regulators have been experienced in public health issues and have successfully protected human health and safety from spread of disease, they have not fully adapted to the changing needs of onsite wastewater system design for increased performance and environmental protection. 
Thus, codes continue to be prescriptive "rule books" that provide no assurance that environmental or public health goals can be met.

 

Today, it is generally recognized that past approaches to manage onsite wastewater treatment system use are no longer adequate.  Prescriptive codes based on empirical relationships and arbitrary standards that emphasize hydraulic performance rather than treatment are not meeting the demands for environmental protection.  Regulatory complacency with system performance after installation cannot continue if treatment goals are to be met.

 

The practice of engineering is a universal constant and is independent of geo-political boundaries. Our licensing board(s) should be gathering information from the success of other programs to ensure a competent work force is readily available.  Reducing entry requirements will not provide a more skilled labor force to meet current demands for the user or designer.  Historical paradigms for designing onsite sewage systems have expired and failed in most states.  Increasing designer knowledge, skills, and abilities provides immediate benefit that society can rely upon.    

CommentID: 57484