On behalf of the Virginia Association of Onsite Soil Evaluators (VAAOSE), we would like to go on record stating our opposition at lowering/reducing the education requirements and years of practice that is currently required to obtain licensure as an Onsite Soil Evaluator (OSE).  Understanding and fully comprehending the technical aspects of evaluating both the soils and site topography of a given parcel of land within the Commonwealth to determine if the site and soil conditions are conducive to the proper function of an onsite sewage disposal system while also taking into consideration public welfare and environmental health safety, is a skill set that comes with years of experience.  Additionally, taking that knowledge and using it to properly design an onsite sewage disposal system that meets both regulatory code as well as the individual needs of the property owner requires a level of professionalism and technical understanding that only comes through years of proper training and experience.  To lower those training standards does not serve in the best interest of protecting the health and welfare of the general public, nor is it conducive to promoting a well-trained and professional licensed class.

We strongly recommend keeping the existing license classifications and specific entry requirements for OSE's the same.

The “journeyman” classification has also been of great concern to many of our licensed OSE members.  It would appear that this classification was brought about by a lack of licensed OSEs working for the Virginia Dept. of Health (VDH), and by DPOR creating this classification, it allowed for newly hired Environmental Health Specialists with the agency to be able to perform soil evaluation and sewage system design services without the necessary field experience (on the job training if you will) and without having to obtain the OSE licensure and simply working under the “supervision” of a licensed OSE working for VDH.  Previously, such individuals would have been classified as “trainees” and would work with licensed OSEs gaining the necessary field experience to later qualify to take the exam to become licensed OSEs themselves.  As “trainees”, these individuals should not have any authority to perform individual site and soil evaluation services.  These services should only be performed and certified by a licensed OSE.  The “trainees” should not be a licensed profession (journeyman), but work as unlicensed “technicians” either in public or private sector service assisting licensed OSEs under the direct guidance and supervision of  licensed OSEs while they learn the necessary skill set required to qualify to become licensed OSE themselves. 

Finally, it would also appear that trying to properly regulate installers, operators, and designers under one chapter is somewhat counterintuitive.  Would it not be more rational and make more sense to establish a separate chapter for each licensed profession? 

We appreciate your consideration of our comments.