I fully support the comment made by Michael Campbell regarding 18 VAC 160-20-82 (interim license).  Adding his proposed language ( "and to any VDH Environmental Health practitioner who has completed the VDH testing and training regimen and is currently engaged in onsite soil evaluation as part of their VDH employment" ) will allow VDH to continue providing uninterupted mandated services and will allow VDH staff a 3-year window to obtain the permanent license.

The benefits of granting the temporary 36-month license to current VDH practitioners far outweigh any real or perceived consequences of allowing VDH staff to continue doing business as usual for the next 3 years.

Mike, thank you for providing a thoughtful, reasonable and appropriate solution to this issue.