|Action||Compliance with Virginia’s Settlement Agreement with US DOJ|
|Comment Period||Ends 7/22/2020|
170 H & 620 D.3
A CAP is meant to describe the steps that will be taken to DECREASE the possibility that a problem will occur again. It is impossible, due to many factors (including human behavior), to expect a problem to NEVER occur again. And failure to meet the expectation of a problem never reoccuring causing another citation is unreasonable and not realistic. The expectation for a problem to never occur again is an impossible standard to meet. 12VAC35-105-170H & 12VAC35-105-620D.3 should be removed from the final regulations.