18VAC160-20-96 B.1 c and d. A BS degree should be required for a professional position. These two sections should be deleted. If these are kept (carrried over from the VDH AOSE regulations)it is especially strange that it is a shorter track to obtain certification under category c. than category b. Four years for a BS plus 2 years of experience vs 2 years for associate’s degree and 3 years of experience.