Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
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9/23/20  12:49 pm
Commenter: Robert REIS

SUPPORT Continued Regulation of Interior Design in Virginia
 

My name is Robert Reis and I am a practicing architect, living and working in Norfolk, VA., doing projects in the higher education, civic, and commercial realms. I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia. Our firm has certified/licensed interior designers that collaborate with the architects, and lead the interior design on our projects. Within the firm we promote professional licensure for all of our staff in their particular discipline. The various forms of licensure insure a certain level of professional standard and work product. This stature can also be important with respect to contract requirements and professional liability. We value the certification of interior designers as an important factor in our work quality and in meeting the expectations of our clients.

It is clear, eliminating regulation of Interior Design would gravely harm Virginia Certified Interior Designers, Interior Design small businesses, and others in the Commonwealth. For example:

– In order to hold a position on a corporate board for a “Professional Corporation,” the employee must be licensed or certified in their profession by the Commonwealth. Eliminating the interior design regulation would prevent interior designers from serving on the board of architectural-interior design and interior design-only firms.

– RFPs (Request for Proposals) and RFQs (Request for Qualifications) in the Commonwealth of Virginia and for Federal Government Projects that include Interior Design Services require that the Interior Designer providing these services be a Certified Interior Designer. Eliminating the regulation would bar Virginia interior designers from submitting for these proposals.

– Job postings for Interior Designers in the Commonwealth and for Federal departments typically require an Interior Designer to be a Certified Interior Designer. Eliminating the regulation would exclude Virginia interior designers from these opportunities.

In Virginia, of the 1,272 interior design establishments in the Commonwealth, 96% are small businesses of four or fewer employees. 83% of these small businesses are women or minority owned. Eliminating interior design regulation would crush these entrepreneurs and small businesses because of the reasons listed in this comment.

Eliminating the Interior Design statute would also harm the Commonwealth. Being a Certified Interior Designer in the Commonwealth provides the public with knowledge that a minimum set of requirements, including education, experience, and testing, has been met. Certified Interior Designers do complex design drafting work in large public and code-regulated spaces like hotels, hospitals, corporate offices, and multifamily housing where public life-safety is implicated. CIDs have a knowledge of building codes, standards, and other laws and regulations that are essential to the safe construction of public and other code-regulated buildings.

Washington D.C., Maryland, Georgia, Tennessee, and Kentucky, all have statutes in place for the regulation of the title and/or practice of Interior Design. In total, 27 states and two federal jurisdictions regulate interior design. No jurisdiction has ever deregulated the practice of interior design.

The interior design statute is not restrictive or protectionist. The title protection law—enacted during the 1990 Session of the General Assembly—does not restrict the scope of practice and serves as the framework for the voluntary certification program. While only certified interior designers may use the title “Certified,” any individual may contract with a client to render services as an interior designer, interior decorator, or similar practitioner if the client so chooses.

Eliminating the voluntary regulation of interior design in Virginia is bad public policy. Continued regulation is vital to the practice, profession, industry, consumers, and the public’s health, safety, and welfare. I ask you to not eliminate the regulation of this profession.

Thank you. 

Robert V Reis, AIA, LEED AP

CommentID: 85465