12VAC5-613-170: Designers, of non-engineered AOSS systems (ie. AOSE designs), should not be responsible for creating and distributing O & M Manuals. This should be the responsiblity of the O & M provider. The O & M provider is being paid for a service and any manuals associated with this service should be provided by them. Licensed AOSE's who are NOT also licensed O & M Providers are being required to fully know and understand O & M regulations as well as dictate the O & M providers responsiblities (ex. 12VAC5-613-170 C 3. & 4.). This entire section (170) should fall under Operator Responsibilities (Section 120) with an exception to systems designed under Section 32.1-163.6 of the Code of Virginia (ie. "engineered systems").