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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2/9/16  10:52 pm
Commenter: bob marshall / cloverleaf env. cnslt., inc.

18VAC160-40-10. Definitions.Master
 

Definitions.Master

Very strongly object to the proposed definition.  This Board fails to recognize that something is very wrong, the introduction of a "master" distinction is far from sufficient to protect the public from recurring crises.

By contrast, "simple permission to play in a market"does not "foreseeably entail permission to roughhouse in that market unlawfully." Kay Elec. Cooperative v. Newkirk, 647 F. 3d 1039, 1043 (CA10 2011)

Suggest the proposed language be removed under 18VAC160-40-10, as follows:

18VAC160-40-10. Definitions.

B. The following words, terms, and phrases when used in this chapter shall have the following meaning unless the context clearly indicates otherwise:

"Master" means an individual who possess the minimum skills and competency to install or maintain onsite sewage system or evaluate soil sites as suitable for conventional and alternative onsite sewage systems and to design conventional and alternative onsite sewage systems.

CommentID: 49534