18 VAC 160-20-82 Interim licensure.

The current expression in the proposed regulation is to issue an interim onsite soil evaluator license to any individual who possesses a valid AOSE certification on the effective date of this chapter. What warrants this format?  I strongly concur with Michael V. Campbell's comments of 2/12/09.  Any Environmental Health Specialist Senior who is currently engaged in onsite soil evaluation as part of their VDH employment should bd included in the interim status classification.

VDH staff have never been required to participate in the AOSE program and if an individual chooses to do so there is no compensation awarded.  Fundamentally what is produced by herding these employees through this hurdle?  In the long term all onsite professionals as these regulations are written will be phased from the interim license status to non interim as they comply with the programs requirements.  Honor these VDH onsite professionals with this basic application of procedural continuity.  What justify's their exclusion?

Current VDH staff have completed the training and testing required of them to act on the behalf of the Commonwealth.  VDH staff at such time they have shown compentency are reclassified as Environmental Health Specialist Seniors.  They have passed the litmus test of competency.