The seven consensus recommendations, and the documents and policies developed to respond to each recommendation, are as follows:

1. VDH must provide regulatory oversight, which includes all duties that do not require a license.  More specifically, VDH will conduct inspections, manage policy, draft and issue operating permits, and maintain and manage records and data.

These actions are already ongoing.  VDH will continue to implement laws and regulations pertaining to onsite sewage systems and private wells, including the review of private sector work.

2. VDH should implement a statewide policy as soon as possible that applicants be encouraged to use the private sector for construction services.  Strategies to use:

1. Educational/Disclosure Strategy:  VDH should provide educational material to applicants outlining the limits of VDH services and encouraging applicants to obtain private services.

There are two components to implementing this recommendation.  The first component is for all local health departments to provide applicants in the onsite sewage and private well program with a “Disclosure Document” (see attached).  This document will be posted in a prominent location in the area where applications are accepted, and be provided to anyone requesting an application.

The second component to implementing this strategy is to create a website based on the information provided in the “Disclosure Document.”  Applicants looking for an electronic copy of the onsite sewage and private well application will be directed to http://www.vdh.virginia.gov/EnvironmentalHealth/Onsite/Application.  This site provides the same information as the “Disclosure Document” and includes a link to the sewage and well application.

2. Service Provider Strategy:  VDH should provide/make available to consumers the names and contact information of private sector providers willing to provide work in that health district (through an easy mechanism such as website or roster maintained by the private sector).

Staff  will let applicants know VDH is creating a list of service providers (OSE, PE, installers, haulers, and well drillers), which can be review at http://www.vdh.virginia.gov/EnvironmentalHealth/Onsite/ServiceProviders.  The site currently states the list is “coming soon” since we have not received contact information from service providers yet.  We expect the first list to go up in early February once service providers have time to sign up.  This list will expand over time as service providers upload their information to the website.  Please let your stakeholders know about the website so they can upload their information (see the link at the bottom of the service provider webpage to sign up).  The intent is to create list similar to the one created for AOSS Operators at http://www.vdh.virginia.gov/EnvironmentalHealth/Onsite/aossoperatorlist.htm. 

3. All Level 1 and 2 reviews will be documented with standard VDH forms.  Copies of all official documents shall be sent to the OSE/PE after the review has been completed.

VDH staff will be instructed to share a copy of our Level 1 and Level 2 review with the private sector OSE/PE whose work was reviewed.  This process will use the existing Level 1 and 2 review forms.  This information will be provided to the private sector OSE/PE when they are copied on the approval or denial letter.

4. Work Product Expectations:  VDH should implement a policy as soon as possible that requires VDH and private sector work to meet the same work product expectations.

Implementation of this recommendation incorporates four different components.  The first component is to require VDH staff to use new VENIS print forms when issuing permits for bare applications.  These new print forms more closely mirror private sector design packages by including: a permit letter, a cover page, a certification statement, the VDH OSEs license number, and page numbering, among other features.  The expectations for the information provided on these forms is outlined in GMP 2015-01.

The second component to address this recommendation is to require VDH staff to generate a system curve for all onsite sewage system construction permits where a pump is required.

The third component is to require all VDH staff to provide scale drawings with all onsite sewage system and private well construction permits.

When combined, the first three components create the new VDH OSE permit package.

The fourth component to addressing this recommendation is a revision to GMP 126.B.  The revised policy, GMP 2015-01, is attached.

Major changes in GMP 2015-01 include:

• New work product expectations for VDH OSE’s.
• Use of the Malfunction Assessment on VDH and private sector repair designs (see attached form).
• VDH staff performing Level 2 inspections on 10% of private OSE/PE design installations.
• Design change allowances (see Part III Section C).
• Prioritization of applications.
• Process for survey plat waivers for private sector designs (see Part II Section F).
• Elimination of the abbreviated design form and revisions to site and soil evaluation report form (see attached).
• Discussion on professional relationship and judgment.

5. Work to be done under Licensure:  Everybody who is doing site evaluations and design should be doing it under the auspices of a licensed individual.

OEHS has reiterated that VDH staff with an OSE license can sign permits issued for onsite sewage systems and private wells. VDH staff who performs work without a license must perform that work under the direct supervision of someone with the license.  The person with the license must sign the permit approval or denial.  

6. Revise GMP 51 to reflect the new proposed model.

OEHS has included revised procedures for prioritizing application in GMP 2015-01  Therefore, GMP 51 has been rescinded.

7. VDH must have clear/transparent reporting.  For any changes to existing practices, the VDH Quality Assurance/Quality Control (QA/QC) must be revised to address the newly proposed model.

Review and revision of QA/QC policy is an ongoing process.  OEHS has set a goal to have any necessary updates completed within the next 12 months.

These are significant changes in the onsite sewage and private well program.  I expect you and your organizations members will have questions.  We will be holding an informational session soon to help outline all of the changes and answer your questions.  I will send you sign up information for that session very soon.  Until that time, if you have any question or comments, please feel free to contact me. I wish you all a Happy New Year.

Sincerely,

Lance Gregory

Environmental Health Coordinator

Office of Environmental Health

Virginia Department of Health

(804) 864-7491