Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Board for Waterworks and Wastewater Works Operators and Onsite Sewage System Professionals
 
chapter
Onsite Sewage System Professionals Licensing Regulations [18 VAC 160 ‑ 40]
Action General Review 2014
Stage Proposed
Comment Period Ended on 2/12/2016
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1/28/16  6:50 pm
Commenter: James Slusser, COD

Objection to 18VAC160-40-210.
 

EXHIBIT H

KR Trapper Davis <krdavis@cpegllc.com> wrote:

Jim, my problem with this bill isn’t about an Installer getting his license … my problem is with an “Operator” being granted a license to manage, operate and maintain an AOSS up to 10,000 gpd without demonstrating they have the “knowledge” to do so … these guys run pump trucks and have the attitude (as demonstrated in their letter) that maintenance is nothing but “pumping and Dumping” … Managing the higher flow systems requires higher math skills, a working knowledge of some chemistry and microbiology, as well as intimately knowing HOW the systems work and WHY they work …[emphasis added] --KR TRAPPER DAVIS (email March 1, 2014)


Objection to the restructuring of "direct supervision" and no examination process for journeymen who will not be DIRECTLY SUPERVISED.  In essence, you are going to leave an untrained, untested individual ALONE to operate a system.  Seems like this undermines the necessity of protecting public health, safety, and welfare.

 

Prerequisites

Exam Required

Education Required

Documented Qualifying Experience

1.

None

No

20 hours of education approved by the board covering the basics of operation and maintenance of alternative onsite sewage systems

One year of full-time experience assisting with the operation and maintenance of alternative onsite sewage systems verified by one or more of the following: an alternative onsite soil evaluator, an alternative sewage system operator, a professional engineer, or an authorized onsite soil evaluator certified by VDH before July 1, 2009

2.

None

No

None

Two years of full-time experience assisting with the operation and maintenance of alternative onsite sewage systems verified by one or more of the following: an alternative onsite soil evaluator, an alternative sewage system operator, a professional engineer, or an authorized onsite soil evaluator certified by VDH before July 1, 2009

         

 Proposal: Provide a mechanism that operators provide DIRECT SUPERVISION until the trainee is fully examined.  How are you going to stop operators from utilizing a "manpower" job sourcing entinty to hire persons that will not be employed for the full 1760 minimum hour requirement for licensure?  This circumvention must be corrected, please address at your convenience.

CommentID: 49389