Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Regulations for Alternative Onsite Sewage Systems [12 VAC 5 ‑ 613]
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2/25/16  11:54 am
Commenter: Jeff Walker

Product Approval
 

In undertaking review and approval of proprietary products the VDH must have adequate standards.

The unfortunate loss of life in Pulaski County was adjudicated to be due in part to the failure of a child safe lid, the department listed for use across the Commonwealth. Having assumed an obligation for product approval does the state have capacity to review product performance and safety for use?

In the future the Commonwealth would be well advised to rely upon accepted engineering standards and testing results such as NSF or Underwriters Labs. Or establish a comprehensive and verifiable set of standards applied uniformly without granting any form of competitive advantage.

This emphasizes a conflict of interest which must be managed in providing in-house design services for development of private property which requires specification of listed products, but conflict with the ministerial duties.

CommentID: 49661