Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Professional and Occupational Regulation
 
Previous Comment     Next Comment     Back to List of Comments
9/29/20  1:17 pm
Commenter: Christine McKinley, DoD/Navy, Naval Station Norfolk

SUPPORT Continued Regulation of Interior Design in Virginia
 

My name is CHRISTINE MCKINLEY and I AM A CERTIFIED INTERIOR DESIGNER IN THE STATE OF VIRGINIA, WHERE I BOTH RESIDE AND AM EMPLOYED BY THE NAVY (DoD). I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia.
 
UNDERSTANDING THE CRITICALITY OF PROFESSIONAL REGISTRATION - AND  IN ORDER TO BECOME A LICENSED INTERIOR DESIGNER IN THE STATE OF VIRGINIA - I INITIALLY ENSURED THAT I OBTAINED AN ACCREDITED DESIGN DEGREEE, EARNING A BACHELOR OF SCIENCE IN INTERIOR DESIGN.  I FURTHER GAINED THE REQUIRED FIELD EXPERIENCE AND KNOWLEDGE TO OBTAIN MY NCIDQ (NATIONAL COUNCIL FOR INTERIOR DESIGN QUALIFICATION); BOTH WHICH ARE PRE-REQUISITS FOR VIRGINIA LICENSURE.

I HAVE BEEN PRACTICING INTERIOR DESIGN FOR 30 YEARS IN THE STATE OF VIRGINIA, AND DEPEND ON MY PROFESSIONAL REGISTRATION TO ENSURE MY CONTINUED LIVELIHOOD.

Being an Interior Designer for the Navy requires both the performance of in-house design as well as the oversight of Architectural and Engineering Firms and General Contractors, in order to execute projects for the DoD.  Our organization requires a Licensed Interior Designer that has a full understanding of Codes and Standards, and that is capable of performing the following:

Project Management:  Contract Administration, Project Coordination, Product and Material Coordination.

Programming and Design:  Construction Drawings and Specifications, Coordination of all Infrastructure (electrical, data, telecommunications and plumbing).  Specify Furniture, Finishes, and Equipment.

Procurement:   Oversight of Collateral equipment packages including the development technical specifications, bidding, bid evaluation and award recommendation, and installation oversight.

It is essential that these duties continue to be executed  by a trained and licensed professional in order to provide continued support for the Navy and Marine Corp missions.

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 knowledge of building codes, standards, and other laws and regulations that are essential to the safe construction of public and other code-regulated buildings.

In light of the pandemic and as Virginians get back to their stores, businesses, and corporate offices, it is Certified Interior Designers who are redesigning and space planning these environments to mitigate COVID risk.
 
Our health is influenced by everything we touch in interior spaces. Disease-causing pathogens, like those that spread COVID-19, can be transferred from person to person, but also through everyday objects like office door handles, restroom grab bars, and schoolroom desks. It is critical to have interior environments that can protect our health by reducing pathogen transmission. Interior designers specify materials and finishes in 90% of residential and commercial construction and renovations and these professionals will be key in protecting the US against the virus.
 
Regulating interior design is a sensible practice. 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.

Christine McKinley, CID

(757) 341-0672

CommentID: 86918