18VAC160-40-490. Licensee responsibility.

B.1 [ The licensee shall sign, date, and include his license number on all final work products prepared or
reviewed and approved by the licensee. For work products performed by a journeyman licensee, the master
licensee providing direct supervision shall sign, date, and include his license number, along with the
journeyman's signature, date, and license number on the final work product. A journeyman licensee shall not
submit a work project as final without the applicable master licensee's signature, date, and license number.

 propose to strike all language than creates a scenario whereby a person not in possession of the master C or AOSE category will be allowed to certify any work.  The WWWOOSSP Board has created a dramatic change to the existing program established by statute.  The Commonwealth should bear no interest in the tracking of potential licensees; a task which is reserved for the licensed professional and or company who will attempt to certify a trainee's working experience.

Suggestion.  Import language from VDH GMP 126 which would include, but not be limited to the following:

2.  All evaluation reports and designs submitted to VDH, whether by an AOSE/PE or by any other person, must be in the form specified in this policy and contain the minimum information required, and shall be certified as substantially complying with the minimum requirements of the Sewage Handling and Disposal Regulations (12 VAC 5-610-20 et seq., the “Regulations”). (See AOSE Regulations, section 70). Whenever an AOSE is required to sign or certify work according to the AOSE Regulations and/or this policy he must, in addition to his signature, apply a stamp or a preprinted or electronic seal bearing the AOSE’s name and certification number to original cover sheets of plans, drawings, plats, reports, and specifications and to each original sheet of plans, drawings, plats, reports, and specifications prepared by the AOSE or someone under his direct control and supervision. Application of the seal and signature indicates acceptance of responsibility for work shown thereon. 

I would like to take a moment to clarify a few issues for the WWWOOSSP Board.  The former VDH AOSE Regulations were crafted using many of the same language that is required for engineers.  During the former VDH program, ALL AOSE's were required to sign, certify, and seal the appropriate work products.  This established a baseline for local officials and state agencies when reviewing licensed professionals work products.  To the contrary,  VDH elected not to comply with the established requirements for their own dubious effect.  

As VDH entered the market place offering design services with VDH licensed practitioners, the necessity for a seal was lost (coincidence?).  While I can not speak for VDH, I can presume that removing a seal would appear to allow licensed professionals to maintain a sense of sovereignty while practicing.  Possible speculation, but to date, WWWOOSSP has failed to provide any answer for not continuing the use of a seal to identity a work product, but also the finality of a design.  The supreme court has held that participation in the marketplace does not provide a shield of sovereignty by state actor while performing market services.  Should the state choose to become a trader, he has no greater merit than private business.