Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Virginia Radiation Protection Regulations [12 VAC 5 ‑ 481]
Action Repeal existing regulations and adopt new regulations with up-to-date radiological health standands
Stage Proposed
Comment Period Ended on 9/29/2005
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9/21/05  12:00 am
Commenter: Dean Broga / VCU

Education, Continuing Education and Experience Requirements for State Inspectors
 

Nothing in these regulations defines either the educational, continuing education or continuing experience requirements for State Inspectors. I think it is in the public healths interest to ensure that State Inspectors meet the same minimum requirements for the inspection of facilities and equipment that are required for Private Inspectors. It has been implied in the past that they do so by job definition but that is not clearly delineated in these regulations and thus allows the State to employee State Inspectors who are not qualified to meet the same level set forth in these regulations. This is not only misleading to the registrant who might choose to use them but an unfair competitive edge since the State is in essence competing with the private sector in this market. At a minimum, State Inspectors should have to meet all of the educational, continuing educational and experience requirements set forth for Private Inspectors if they are going to provide inspection services for a fee.

CommentID: 172