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.