Commenter:
Michael V. Campbell, Henrico Health Department (VDH)
Interim licensure for experienced VDH staff
18 VAC 160-20-82 Interim licensure…
“The Board shall issue an interim onsite soil evaluator license to any individual who possessed a valid authorized onsite soil evaluator (AOSE) certification issued by the VDH on the effective date of this chapter…”
Recommendation: add “and to any VDH Environmental Health practitioner who has completed the VDH training and testing regimen and is currently engaged in onsite soil evaluation as a part of their VDH employment.”
Justification: VDH local health departments employ over 200 Environmental Health practitioners for whom onsite soil evaluation and design of conventional systems is a primary job duty. These individuals have completed extensive formal training in soil characterization, system design, and regulatory requirements. They have completed both classroom and field testing. It has never been a condition of employment or expectation that they attain the AOSE certification as this certification was primarily intended for persons practicing in the private sector. Granting an interim license to these trained and experienced staff seems reasonable to facilitate continued performance of their mandated public service and provide a transition period for VDH to modify its personnel practices to include licensure as a future condition of employment.
18 VAC 160-20-96 Qualifications for licensure…
“B, 1, Conventional onsite soil evaluator…
b. 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…
c. Three years… under the direct supervision of a licensed conventional onsite soil evaluator or of a licensed alternative onsite soil evaluator...
d. Eight years… under the direct supervision of a licensed conventional onsite soil evaluator or of a licensed alternative onsite soil evaluator…
Recommendation: add “or a VDH Environmental Health practitioner who has completed the VDH training and testing regimen.”
Justification: Prior to the date when these amendments become effective there will be no one licensed as an onsite soil evaluator to provide the required supervision (“under the direct supervision of a licensed conventional onsite soil evaluator or of a licensed alternative onsite soil evaluator”), thus this language seems to disqualify all experience prior to the implementation date. Was that the intent of the Board?
VDH local health departments recruit Environmental Health practitioners for whom onsite soil evaluation and design of conventional systems is a primary job duty. These individuals generally have a B.S. in Environmental Health or a natural science and will complete extensive formal training in soil characterization, system design, and regulatory requirements during their probationary periods. They will complete both classroom and field testing. During the first three years of implementation, newly hired VDH staff will, at best, be working under the direct supervision of a person holding an interim soil evaluator license. The suggested added language seems reasonable to facilitate training and development of newly hired VDH staff to include licensure as a condition of continued employment.
