Existing structures / property with an AOSS installed prior to July 1, 2009, should have a requirement to be "inspected" or certified by a licensed operator.  Then the owner of the property may "certify" or attest in writing that the system is operating in accordance with design / permit annually after that period.

Existing structures/ property with an AOSS installed prior to July 1, 2009, that have a change in ownership should be required to have an inspection / certification by a licensed operator, followed by a requirement to maintain a "relationship" with a licensed operator.  These existing AOSS systems should be sampled on a routine basis, and brought into operating compliance with the current rules and regulations.

The current changes / alterations to the health department's VENIS reporting system do not appear to meet the requirements for an online data reporting system as set forth in the COV 32.1-164.8 H.3

3. A statewide web-based reporting system to track the operation, monitoring, and maintenance requirements of each system, including its components. The system shall have the capability for pre-notification of operation, maintenance, or monitoring to the operator or owner. Licensed operators shall be required to enter their reports onto the system. The Department of Health shall utilize the system to provide for compliance monitoring of operation and maintenance requirements throughout the state. The Commissioner shall consider readily available commercial systems currently utilized within the Commonwealth;

In the demonstration site previewed, it appears that VENIS does not allow or have the capability of pre-notification to the operator and/or owner.

Though amending the Code of Virginia is outside of this comment or regulatory action, an amendment to the new regulations allowing operators to use one or more commercial systems such as Carmody Data Systems, Online RME and integration of select data from that system to VENIS needs / should somehow be included.  As stated in the COV, it appears that an operator MUST use the HD's VENIS system if that is the system being used by the health department.  My company currently has in excess of 1,500 records in the Carmody Data Systems online data base, and duplication of data entry IS NOT cost beneficial.  The Carmody Data System is used by nine manufacturers of AOSS as their national data reporting system, and is used by several counties in the Commonwealth.