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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3/5/09  11:34 am
Commenter: Andrew Carter, AOSE

Transition Recommendations
 

Is our industry really that badly broken?  VDH has been regulating the industry, with or without the AOSE program, successfully for years now.  From what I can gather, the transition between VDH and DPOR should be about licensure and not about revamping the program.  So my recommendations are to

- Allow alternative OSE's to evaluate soils and sites and design alternative and conventional septic systems (as allowed under the current program).  If one can evaluate soils and sites and design an alternative system, than they sure as well can evaluate and design a conventional system.

- Likewise for installers-  Allow alternative system installers to be able to install alternative and conventional septic systems.  If an installer can install an alternative septic system than they sure as well have the ability to install a conventional septic system.

- Grandfather all current AOSE's, in good standing, to become alternative OSE's as of July 1, 2009.  All AOSE's under the current program can propose conventional or alternative septic systems designs and perform site and soil evaluations.  The exception seems to be that AOSE's cannot propose alternative septic system designs in parts of Northern VA.  If one is allowed to propose an alternative septic system design and perform a site and soil evaluation now, WHY shouldn't one be able to do the same under DPOR?  WHY do we need a re-examination and WHY should past examples of approved proposals be required?  I understand these requirements for future OSE's, but just because DPOR is going to be overseeing the industry, WHY are AOSE's now asked to do more? 

- Allow all parties, if they qualify, to be able to hold multiple licensures.  An individual should be able to be a conventional and an alternative OSE.  Furthermore, an OSE should be able to install septic systems and be an operator as well. 

Does one who obtains a commercial driver's license lose the ability to drive a non-commercial vehicle?  NO

Could an architect design a building and then have his/her firm construct the building?  YES

Do automobile manufactorers design AND produce automobiles and then offer maintenance and repair services to the vehicles that are purchased?  YES

Why should it be any different for the onsite industry?

CommentID: 6885