I really don’t have any issues with the proposed regulations.  However, the program has been around for a relatively short period of time and appears to be expanding considerably.

There appears to be some confusion and problems regarding the Journeyman concept, particularly in the case of Contractors and Operators.  Concerns include that there are evidently no real qualifications or testing, plus no time limit on when the licensee would have to move up to the next level.  It could be inferred that all employees would need to have a Journeyman license, resulting in an unnecessary administrative and economic burden on the employer.

It is my impression that Journeyman concept arouse out of a concern regarding non OSE practitioners employed in the public sector.

In other states when Sanitarians are hired they are typically a newly graduated student with bachelor’s degree.  There is a requirement of work experience prior to being able to take the Sanitarian registration test.  Lets say one year.  An individual is hired as meeting the educational requirements with the understanding they will be required to be registered within some period of time, say eighteen – twenty four months from the hiring date.

For the most part new EHS’s in Virginia are required to have bachelor’s degree, although I have heard that associate degrees have been accepted.  The requirements for OSE’s licensure for a given educational background is outlined in the regulation.  In this case, the public sector, the Journeyman license is essentially a provisional license, held until such time as the experience, and continuing requirements are met.  At that point the individual should move up in the license hierarchy by successful completion of the examination.  This situation is really not DEPOR’s responsibility or problem.  The government should be responsible to require eventual OSE licensing, within some specified time period as a condition of employment. 

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