Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Professional Soil Scientists, Wetland Professionals, and Geologists
Regulations for the Geology Certification Program [18 VAC 145 ‑ 40]
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8/14/23  3:34 pm
Commenter: Andrew Owens, PG

In Support of Licensing Geologists

I am writing in support of maintaining the regulation of the practice of geology in the Commonwealth of Virginia.  While I appreciate taking opportunities to reduce regulation when it will not cause public harm, the practice of geology, including developing dam strategies, blasting plans, remediation of contaminated soil and groundwater, as well as many more infrastructure concerns, is exactly the wrong area to deregulate.

Below, I will briefly provide information regarding why licensure of geology is important to protect the public including health, safety, environment, and fiscal considerations and why it is important for Geology to be licensed as a unique profession. 

Public Protection through Licensure

The ASBOG® Fundamentals of Geology Examination is a requirement for a person to become a Certified Professional Geologist in the Commonwealth of Virginia and to offer geologic services to the public in the other 30 States that register geologists by examination. Pass-fail analyses of the Fundamentals of Geology Examination indicate that nearly 50 percent of the applicants who take the examination lack the knowledge and experience to practice geology at a minimum competency level.

Much of today’s geological practice affects the health, safety and welfare of the public, the environment, and the economy and feasibility of engineered works. Thus, the public deserves to be protected.

Unqualified geologists, who are employed in jobs that affect the public, place an undue risk on the health, safety and welfare of that public. The risks include:

  • The possibility of an error that will cause a loss of life or property
  • The higher costs of supervision
  • The costs of repeating incorrect and incomplete work
  • Lower cost/benefit ratios brought about by an inability to do efficient work

The registration examinations used by State Boards of Geology (including Virginia) to complete an applicant’s registration are carefully developed and designed by ASBOG® and routinely updated to reflect changes in the profession. The initial step in developing an examination is to carry out a task analysis. The task analysis is based on a survey of registered geologists to determine:

  • The amount of time spent on a specific task;
  • The importance of the task in protecting the public; and
  • The extent of competence required for an entry level geologist at the time of initial licensure.

The results of these three independent responses are used to determine the relative significance of each content area on the Geology Examinations as a requirement for a person to become a Licensed Professional Geologist. Pass-fail analyses of the Fundamentals of Geology and Practice of Geology Examinations indicate that nearly 50 percent of the applicants who take the examination are unqualified to practice geology. Further evaluation of the results from decades of testing results indicates that those not passing the ASBOG® examination(s) lack the required knowledge and/or experience to offer geologic services to the public in a manner that would protect the health, safety, and welfare of the public, the environment and/or the economy.

Additionally, the results of the task analysis are used to determine the relative significance of the tasks that are performed by geologists and used to set the blueprint for each of the ASBOG® examinations - one for the Fundamentals of Geology and one for the Practice of Geology. If constructing geologic maps is the most significant task, then the examination will have more questions on constructing geologic maps. If, on the other hand, a task is determined to be the least significant task, it may be dropped from the examination all together. The blueprint developed based on the task analysis is the template for the examination and ensures that it represents the current practice of the profession.

Subject Matter Experts who represent the full spectrum of the profession are brought together to write and review questions for the examination. These experts prepare questions in their field that other experts will review and approve. The criteria for a question include:

  • Does it have only one answer?
  • Is it related to a blueprint task?
  • Is it related to public protection (health, safety, environment, and fiscal)?
  • Is the question clear and direct?
  • Is it written at the entry level?
  • Is it free of trickery?
  • Does it avoid assessing trivia?

If the question passes each of these criteria it will be approved for the examination database. Prior to and after a question has been used on an examination it is reviewed and evaluated by the subject matter experts from each of the States where registration by examination is required. The first step in the evaluation of each examination is to require these experts to take the examination. The experts, working as a committee, review each examination question to determine:

  • The correct answer,
  • That there is only one correct answer, and
  • That the question meets the criteria listed above.

If the question passes review, the experts assign a difficulty score to the question. The score for each question is combined to determine the degree of difficulty of the examination, which is then compared with the minimum level of competence required for a person to practice geology before the public to ensure that every administration of an ASBOG® examination meets this requirement.

Importance of the Licensure of Geology as a Profession

Geologists make use of their special knowledge for the benefit of the public: from the obvious, e.g., exploration and development of mineral resources plus development of water resources to the less obvious, e.g., evaluating the stability of foundations for buildings, dams, bridges and roadways, plus many others. Few other professions affect the public more than geology, especially through collaboration with the construction and engineering professions. "Civilization exists by geological consent, subject to change without notice," a popular saying with much merit.

Why register geologists?

The application of geologic knowledge and experience are integral to many actions involving public health, safety, and welfare (including financial). Professional geologists working with others can determine and apply sound geologic knowledge and procedures that will serve to avoid endangerment of the public or the environment.

How will the public be protected?

First, no one may be represented as a Professional/Registered Geologist unless registered by the State in which they practice. Second, State registration boards are typically granted the authority to monitor and enforce the registration laws, thus ensuring the practice of geology in a competent manner by Professional Geologists within that State.

Who can become registered as a geologist?

Currently, in Virginia, individuals who have a college degree in geology and five years of geological work experience can initially qualify for registration. In addition, the successful completion of two four-hour long examinations to demonstrate minimum competence in both the fundamentals and the practice of geology.

Registration assures that qualified and reputable individuals provide accurate geologic information to the public. Examples of the practice areas covered by registration include the following:

  • geologic mapping
  • groundwater resource and development protection
  • mineral-resource evaluation
  • oil and gas development
  • safe oil, gas, water, or mineral drilling
  • accurate and reliable information to government agencies for public use
  • environmental geology issues
  • land surface stability
  • solid waste siting
  • toxic, nuclear, and hazardous waste disposal siting
  • contaminated soil investigations and remediation
  • groundwater investigations
  • mined-land reclamation
  • acid mine drainage suppression and remediation
  • dam and impoundment construction
  • highway, roadway, and bridge construction

Some people note that geology sounds a lot like engineering. So, what's the difference?

Geologists are trained to consider the entire physical environment, the materials that compose it (rocks, soils, and water) and the dynamic physical and geochemical processes that drive it. Engineers are more concerned with facility design including material and structural properties along with construction and constructability considerations.

Geologists and engineers generally work together making sure that all natural and man-made influences are considered in a project or setting.

Why don't geologists register as engineers?

Geologists have education and professional experience that is specifically directed toward investigating and using the earthen materials that affect the public or natural spaces. No other profession has comparable education and professional experience.

Why not hire engineers to certify geologists' work?

For public protection, persons can only certify geological work for which they were trained in the fundamental geologic principles and have the necessary experience. Geologists are trained and have experience in geologic interpretation of earthen materials; engineers are trained and have experience in designing and building. These are two distinctly different professions. However, because of the close relations between those who interpret and those who design and build, geologists and engineers must work together in a collaborative fashion.

How do they work together?

Geologists interpret, engineers design and build. Geologists investigate earth materials and processes and advise how to compensate for those conditions to assure safety. Engineers take this information, and working with geologists and others, determine how to design and build safe structures in a cost-effective manner.

In closing, I think you will agree that the continued regulation of the practice of geology is vital to the protection of public health for all citizens of  the Commonwealth of Virginia.


Andrew Owens, PG

CommentID: 218685