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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3/4/09  3:20 pm
Commenter: Frazier Consultants

Design Criteria for OSE
 

Our family has ben in the business of evaluating soils for potential drianfield use since 1978.  My fother has worked in both the Public Sector (EHS) and Private Sector.  Both my father and I are certified professional soil scientist and my father is also an AOSE. 

In 2000 our firm (family) made a conscious decision not to design or own alternative drainfields.  The following is our reasons.

1.  Fauquier County Requires all alternative drainfields of any type to be stamped by a professional engineer including Puarflo and AdvanTex,

2. Prince William County requires all conventional installations to be timed dosed so an engineered pump curve is required.  The only system an AOSE can deisgn in Prince William County are Puraflos and AdvanTex type sytems with out double pumps.

3. Fairfax requires engineered plans for all non-convnetional systems

4. Loudoun County required engineeered designs on every thing except Puraflo and AdvanTexes.

All of these counties will not allow an AOSe to design pretreated convnetional systems with out and engineered stamp or allow Puraflos to drip irrigation systems to be designed by an AOSE.

With all of these restrictions and the feeling in our company that having a professional engineer review our stakeout data and perliminary designs was a much safer and responsible way to proceed.  We did not do any dewsigns except convnetional.

Now DPOR is trying to say we are not qualified to evaluate soils for alternative systems because we have design the miniumm number. This is crazy,  Evaluations and designs are 2 separte issues and should be treated that way.

A design is only as good as the evaluation.  An AOSE/Engineer may deisgn a system perfectly but it the evaluation is done incorrectly the system is doomed for failure.

A perfect evaluation and all the right calls can be ruined by a poor deisgn.

Since when did our firms ability to evaluate soils depend on how systems we designed.  We do take continuing education credits in design, we take them in soils evaluation, system overview, describing soils and the benefits of technology.  We do not take course in CAD design, hydaulic calulations, fluid dynamics etc.

I beleive that some in our industry are trying to move away from the basis of our job description.  We are soil scientist and site evaluators.  Nowhere in either of those is the word designer.  Even the VDH recognized many years ago that system deisgn (except for conventional systems) was beyond their purview.

The criteria for a Convnetional and Alternative Onsite Evaluator should have absolutley nothing to do with how many designs I have done.  It should have everything to do with the evaluation process I used, the sucess of the systems I have permitted, the results of the Level II reviews of my work and my stutus as an upstanding, respected induvidual in the soil scientist and onsite communities.

CommentID: 6877