I fully support the petition.  Well defined regulations and regulatory oversight regarding supervision and practice of certified substance abuse counselors (CSAC) who are not licensed, nor working toward licensure, to practice independently is absolutely necessary.  The law is vague and has the potential to put clients’ welfare in harm’s way by CSAC’s practicing independently, by misinterpreting “unless under supervision”.  The law clearly states that residents in counseling may not practice independently until they are fully licensed.  The regulations need to be just as clear with CSACs.