Virginia Regulatory Town Hall
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Board for Professional and Occupational Regulation
 
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9/2/20  11:47 am
Commenter: Sorrell Design

The Safety of Building Occupants Depends on Continued Regulation of Interior Design
 

My name is Steven Sorrell and while I live and have an office in DC, complete a lot of work in Virginia. I write this comment in STRONG support of the continued regulation of the interior design profession in Virginia.

Virginia has already lessened the interior design profession in a negative way, where we are limited on what we can sign and stamp and submit for permit review.

Since I practice in DC, it would be nice to see VA follow DC's lead on the professional stance for Interior Designers. A professional interior designer understand the codes required to buildout the space. For those who have taken and passed their exams, they should be able to submit drawings for permit without some of the current limitations. Interior designers tend to actually understand the interior space better than architects, with how it is used, current trends, spacing, etc. If a designer needs to make a change that may impact structural, they can have a structural engineer included in the process and submission (this is something that architects would have to do as well). 

A lot of interior projects are actually completed by an interior designer and then simply approved by an architect. So why is this additional barrier being added? To me it's also ironic, as I have trained many architects, that I cannot sign and stamp drawings, yet those I've trained can. 

Virginia has always been a great place for business, however with these past regulations and the new ones coming down, it only further hurts my business. I already have to have extra expenses for an architect to stamp and sign my documents in order to be submitted. If this continues further, I don't see any point of practicing in Virginia. I'm sure many other designers will as well. While some may feel that isn't a huge impact, I would like to remind you that we manage everything inside of the shell. We are not just responsible for selecting finishes and furniture, but we help make the interior environment a better place for the tenant and others.

Interiors are very important as that is where people tend to spend a majority of their time, and so we need to make sure we have professionals who understand what is needed to make these environments the best they can be.

It is clear, eliminating regulation of Interior Design would gravely harm Virginia Certified Interior Designers, Interior Design small businesses, and others in the Commonwealth. For example:

– In order to hold a position on a corporate board for a “Professional Corporation,” the employee must be licensed or certified in their profession by the Commonwealth. Eliminating the interior design regulation would prevent interior designers from serving on the board of architectural-interior design and interior design-only firms.

– RFPs (Request for Proposals) and RFQs (Request for Qualifications) in the Commonwealth of Virginia and for Federal Government Projects that include Interior Design Services require that the Interior Designer providing these services be a Certified Interior Designer. Eliminating the regulation would bar Virginia interior designers from submitting for these proposals.

– Job postings for Interior Designers in the Commonwealth and for Federal departments typically require an Interior Designer to be a Certified Interior Designer. Eliminating the regulation would exclude Virginia interior designers from these opportunities.

In Virginia, of the 1,272 interior design establishments in the Commonwealth, 96% are small businesses of four or fewer employees. 83% of these small businesses are women or minority owned. Eliminating interior design regulation would crush these entrepreneurs and small businesses because of the reasons listed in this comment.

Eliminating the Interior Design statute would also harm the Commonwealth. Being a Certified Interior Designer in the Commonwealth provides the public with knowledge that a minimum set of requirements, including education, experience, and testing, has been met. Certified Interior Designers do complex design drafting work in large public and code-regulated spaces like hotels, hospitals, corporate offices, and multifamily housing where public life-safety is implicated. CIDs have a knowledge of building codes, standards, and other laws and regulations that are essential to the safe construction of public and other code-regulated buildings.

In light of the pandemic and as Virginians get back to their stores, businesses, and corporate offices, it is Certified Interior Designers who are redesigning and space planning these environments to mitigate COVID risk.

Our health is influenced by everything we touch in interior spaces. Disease-causing pathogens, like those that spread COVID-19, can be transferred from person to person, but also through everyday objects like office door handles, restroom grab bars, and schoolroom desks. It is critical to have interior environments that can protect our health by reducing pathogen transmission. Interior designers specify materials and finishes in 90% of residential and commercial construction and renovations and these professionals will be key to protecting the US against the virus.

Regulating interior design is a sensible practice. Washington D.C., Maryland, Georgia, Tennessee, and Kentucky, all have statutes in place for the regulation of the title and/or practice of Interior Design. In total, 27 states and two federal jurisdictions regulate interior design. No jurisdiction has ever deregulated the practice of interior design.

The interior design statute is not restrictive or protectionist. The title protection law—enacted during the 1990 Session of the General Assembly—does not restrict the scope of practice and serves as the framework for the voluntary certification program. While only certified interior designers may use the title “Certified,” any individual may contract with a client to render services as an interior designer, interior decorator, or similar practitioner if the client so chooses.

Eliminating the voluntary regulation of interior design in Virginia is bad public policy. Continued regulation is vital to the practice, profession, industry, consumers, and the public’s health, safety, and welfare. I ask you to not eliminate the regulation of this profession.

Thank you.

CommentID: 84368