I am submitting public comments on behalf of the Virginia Waste Industries Association (VWIA), whose members own and operate commercial waste collection, recycling, and disposal facilities, as well as provide consulting and financial services to the waste industry.  The VWIA supports the current regulations for the training and licensing of waste management facilityoperators in Virginia.  Ensuring that waste management facilities are operated by trained and licensed professionals helps ensure that the current waste management regulations are being properly followed, increases safety, and reduces potential impacts to the human health and the environment.  Additionally, the Virginia Department of Environmental Quality (DEQ), whose responsibility includes reviewing, inspecting, and permitting solid waste facilities, would be at a disadvantage if facility operators were not properly trained and licensed. This disadvantage could increase the burden to the DEQ staff requiring more frequent inspections and training for those individuals who may have inadequate training.

Alabama instituted Landfill Operator licensing requirements in 2010.  Over the next few years, the number of Notices of Violation (NOVs) decreased from almost 500 to 100.  This is evidence that such requirements benefit the environment and the regulated community and increase compliance.

The only comment on the current regulations would be the clarification of 18VAC155-20-140.B Examinations.  Specifically, in regard to the more recent requirement by the testing centers to make the exam a closed book exam.  It is our understanding that the Board is currently looking into the pass/fail rate for the exam and we would strongly recommend that that the Board take that into consideration when determining if the waste management facility operators exam should remain a closed book exam.  If the exam remains closed book, then we recommend the questions be reviewed for appropriateness, as some questions are obscure and are not appropriate for a closed book exam.