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
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals Regulations [18 VAC 160 ‑ 20]
Action Amend regulations to license onsite sewage system professionals.
Stage Proposed
Comment Period Ended on 3/6/2009
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1/19/09  8:28 am
Commenter: VDH Employee

Definition Change: Experience
 

The definition of experience includes "the time spent under the direct supervision of an authorized onsite soil evaluator, onsite soil evaluator licensee, onsite sewage system installer licensee or onsite site sewage system operator licensee for the purpose of obtaining the necessary competence to qualify for a specific license."

Ok, this definition does not make sense on several levels.  According to the statement I can work as an installer for four years and that would allow me to sit for any of the licenses (operator or soil evaluator).  Why would DPOR think that experience installing sewage systems should qualify for experience in designing systems or performing site and soil evaluations?  That simply does not make sense.

Next, the definition says time spent under the direct supervision of an authorized onsite soil evaluator.  Ok, but AOSEs no longer exist on July 1, 2009.  Unless the definition says "under the direct supervision of someone who previously held an Authorized Onsite Soil Evaluator," then the definition makes no sense.

Third, experience should include the design and installation of treatment works.  Contractors install both large and small treatment works.  These installations can include alternative discharging systems, spray irrigation, or wisconsin sand mounds.  Some of these installations would not be considered "onsite sewage systems".  If a contractor is installing these higher level systems, then that experience should qualify, not just the experience they have installing less complicated systems.

I recommend that you add the phrase, "operate, design, evaluate, inspect, install treatment works".  That way everybody who is doing work in higher level systems can have that experience count.

DPOR and Board need to go back to the drawing board on some of these proposed definitions.  You need to be more precise in the terms and phrases used.

CommentID: 6723