Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
Guidance Document Change: This policy outlines the procedure for means testing of owners who petition the Virginia Department of Health (VDH) for onsite sewage and private well evaluation and design services pursuant to § 32.1-248.4 of the Code of Virginia (the Code). This policy also establishes Hardship Guidelines whereby VDH may serve as a provider of last resort for onsite sewage and private well evaluation and design services pursuant to § 32.1-248.4 of the Code.
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6/20/19  3:40 pm
Commenter: James B Slusser

Authority Statement
 

Virginia Department of Health proposed policy 2019-01 conflicts with public policy.

Currently, this proposal attempts to circumvent national public goals by maintaining status quo.  VDH can not make a better tomorrow by clinging to a failed program.  Why should VDH adopt public policy to remove themselves from the market place?  The answer was best quoted by Mr. Dwayne Roadcap, former manager of Virginia Department of Health in 2006;

"The answer is simple: because VDH has better uses for its resources and the legislature has said that VDH must accept private sector work.  VDH’s current reality consists of high staff turnover, low morale, and conflict (amongst) itself and with private sector professionals). VDH regulates private sector service providers while simultaneously performing the same services. VDH’s business model focuses resources before sewage systems are used and when there is no risk to public health. When VDH was the sole service provider, this model made sense. Now, a new model is needed because private sector service providers can perform direct services, which allows VDH to shift resources toward risk assessment and risk management—a previously ignored community need. By inculcating the 10 Essential Services into VDH training and requiring VDH field managers to assess their programmatic activities using the 10 Essential Service, it become self-evident to staff that VDH’s historical role does not adequately promote healthy homes, workplaces, or communities."

 

Can the VDH please advise how this policy will create better public health outcomes given their refusal to adopt the 10 Essential Services into the current business model?

Thank you

 

 

CommentID: 72621