The Board defines Sewage Handler and then says that you need one year of sewage handling experience to be a conventional system operator without a GED.  A Sewage Handler simply pumps sewage from a septic tank and driving it to a wastewater treatment facility.  Why does the Board think that you need to have one year of full time experience pumping a septic tank to qualify operating a conventional system?  Also, the definition of sewage handler includes a reference to the health department's regulations, which the health department is in process of changing.  What happens when the references in these regulations are no longer accurate with another set of regulations?  Seems like you should define the practice and not reference another regulation as part of the definition.

It seems odd that the only reason sewage handling is defined in the regulations is so that you can require one year of that experience to operate a conventional system.  How about requiring NSF certification to become an operator for alternative or conventional systems?  How about not defining pumping crap as qualified experience to operate a conventional system?  Why do you need a definition for pumping septic tanks?

Here are couple more definitions with a regulation/law reference that seems odd:

“Sewerage system” means pipe lines or conduits, pumping stations and force mains and all other construction, devices and appliances appurtenant thereto, used for the collection and conveyance of sewage to a treatment works or point of ultimate disposal, as defined in the Sewage Handling and Disposal Regulations (12VAC5-610-10 et seq.).

"Wastewater works" means a system of (i) sewerage systems or sewage treatment works serving more than 400 persons, as set forth in §62.1-44.18 of the Code of Virginia; (ii) sewerage systems or sewage treatment works serving fewer than 400 persons, as set forth in §62.1-44.18 of the Code of Virginia, if so certified by the State Water Control Board; and (iii) facilities for discharge into state waters of industrial wastes or other wastes, if certified by the State Water Control Board.

Ok, you define sewerage system using the health department regulation and then this word is used to define wastewater works, which is defined under DEQ's code language.  Why?  The term sewerage system is only used to help define wastewater works.  Why does the health regulation need to help define what is in DEQ's code?  This seems very strange.