I am licensed under the OSE regulations and object to the loss of the expectations captured under sections of 12VAC5 615. The AOSE Regulations are the only place where the licensed professional’s duties and responsibilities are codified in law and should not be lost without the capture of fundamental standards in place since 2002.

OSE’s have relied upon these regulations to establish standards of practice used to determine whether a site meets the conditions set forth in the Code of Virginia under the Sewage Handling or Private Well Regulations, and how work presented on behalf of a client is considered by the Department of Health under procedures necessary to secure timely responses to applications.

I am concerned that with the lack of a regulatory basis (615) standard of practice will be significantly compromised or non-existent.   

The 615 Regulations have components which ought to be captured by VDH or the DPOR WWWOOSSOP Boards and incorporated in the technical, ethical, and procedural considerations which define and regulate our profession instead of being stricken from the record.

The Agency needs to reconsider the means to amend or abandon these statutes which document the expectations of our work and the procedures by which the public’s interests are considered. These are captured and referenced back to 12VAC5-615 in GMP126B- Standards for Applications with Supporting Documentation from the Private Sector; however there are many issues under the regulation and the policy which deserve clarification and support, particularly clarifications of the appropriateness of submissions to VDH by non-OSE’s, relationship to Chapter 613, and submissions under § 32.1-163.6 of the Code of Virginia, to standardize the practice of site evaluation and design.