Action | Amend Definitions of Supervision, SDS Experience and Document Requirements for Installers |
Stage | Fast-Track |
Comment Period | Ended on 11/7/2012 |
I object to the proposed regulation changes be “fast tracked”. They should be review in a public forum.
Although the changes appear to be addressing installers only, I find certain items troubling and in need of clarification.
The definitions of Direct Supervisor and Direct Supervision as proposed are no longer specific to licensure.
Secondly, 18VAC 160-20-97C. (5) 3a inserts the term “authorized VDH employee”. Although the term arises out of language specific to installers, the undefined term, coupled the above definitions is of concern.
Could these changes be subject to interpretation in the future and applied to field EHS’s under the “supervision” of an “authorized VDH employee”?.
I am in full agreement with previous comments.