Guidance Document ID 6790 (Contractor License Requirement for Onsite Sewage System Maintenance), currently listed under DPOR’s Guidance Documents in Effect for the WWWOOSSP Board, is being proposed for deletion. The stated reason is that its content will be incorporated into Guidance Document ID 2959 (Board of Contractors Policies & Interpretations), which is housed under DPOR and listed in Guidance Documents in Effect for the Board of Contractors.

My concern is that if GD 6790 is removed from the WWWOOSSP Board’s guidance listings, individuals working in the onsite sewage industry may no longer be aware that this guidance exists or know to look to the Board of Contractors for clarification on licensing requirements. This topic has generated questions in the past, which is why a guidance document dedicated to the onsite industry was created initially.

Has it been planned for GD 2959 to also be listed under the WWWOOSSP Board’s Guidance Documents in Effect so it remains visible to industry stakeholders? If so, I would also note that GD 2959 is a broad, wide-ranging document containing far more information than is necessary for the onsite industry. The onsite board’s page should ideally provide focused guidance specific to onsite sewage professionals.

There are also many new individuals entering the industry, and ease of access to clear, relevant, and industry-specific information benefits everyone—licensees, regulators, and the public. Without a clearly labeled, onsite-specific guidance document, important licensing information may be overlooked or misunderstood.

Because this is not a situation where the guidance has been fully codified and made unnecessary, I believe it remains important that licensing clarification be presented in a guidance document expressly directed to the onsite industry and accessible through the WWWOOSSP Board’s section on Town Hall.

I would also like to further clarify the need for guidance addressing situations where dual licensure requirements arise between the Board for Contractors and the WWWOOSSP Board. Questions frequently come up regarding when an individual must hold a contractor’s license in addition to a WWWOOSSP license. The current guidance focuses narrowly on the definition of “maintenance,” but real-world scenarios extend beyond that.

Many within the onsite industry—particularly Onsite Sewage System Installers who contract work directly to the public—may not realize that a separate contractor’s license is required under the Board for Contractors. The existing WWWOOSSP statutes and regulations do not indicate this crossover, nor do they reference the need for an CDS or ADS classification when installation or construction-related activities fall under the Board for Contractors’ authority. As a result, WWWOOSSP licensed installers may unintentionally perform work requiring contractor licensure without knowing they must also hold the appropriate CDS/ADS classification in the Commonwealth of Virginia.

Providing clear, accessible guidance on when dual licensure is required—and clarifying that certain installation-related tasks fall under contractor classifications—would be highly beneficial to the industry. Some individuals entering the field are new, and ensuring they can easily understand when additional licensure is needed protects both professionals and the public.

For these reasons, I believe more explicit and comprehensive guidance is necessary so that licensees can confidently determine when work performed falls exclusively under WWWOOSSP authority or when it also requires licensure through the Board for Contractors. It is integral that this information be clear and easily accessible to those within the onsite industry, as many may believe the WWWOOSSP Board is the exclusive licensing and regulatory authority governing their industry.