ISDS 



means by which to resolve issues, fortify regulatory language, or update program 

 approach. Recommendations which coincide with those of the ISDS Task Force are 

 presented in italics. 



TRAINING AND LICENSING 



Findings and Concerns 



Because severe health and environmental hazards may result from installation of ISDS 

 designed and sized on the basis of incomplete or inadequate site evaluation, the importance 

 of the site evaluation process, and its interpretation, cannot be overemphasized 



Many engineers, contractors, surveyors, drain-layers, sanitarians, ISDS installers, waste 

 haulers, building inspectors, and other town and state officials, as well as the public clients 

 they serve, are insufficientiy informed regarding the purpose of site evaluation, and the 

 critical roles which proper design, installation, and maintenance of ISDS play in preserving 

 the consumer's investment, protecting public health and preventing water quality 

 degradation. 



Although DEM currentiy licenses ISDS installers and waste haulers in accordance with 

 DOH standards, existing licensing procedures are out of date and were designed to address 

 limited health-related concerns rather than complex joint issues of water quality and public 

 health. Septage haulers are presentiy required to submit manifests under the state 

 hazardous waste law, but the provision has not been enforced by the Division of Air and 

 Hazardous Materials. 



Recommendations to RIDEM 



*A training handbook describing principles of ISDS function, potential 

 water quality impacts, and the basics of ISDS protection and maintenance 

 should be prepared. The handbook should be distributed to all applicants for ISDS 

 permits, to towns for distribution to homeowners, and to the general public. Save the Bay, 

 Inc. has published a useful pamphlet of this nature. 



*A technical training manual should be prepared for DEM staff, designers, 

 installers, contracting professionals, building inspectors, and state and 

 town officials. The handbook should describe the basis and rationale of site evaluation, 

 the principles of ISDS function, issues of concern in installation and maintenance, and 

 potential water quality impacts of failed systems. 



***Develop a mandatory licensing and certification program for all 

 professionals associated with ISDS design, siting, installation, inspection, 

 and maintenance, including performance of percolation tests. Program staff, 

 engineers, registered surveyors, sanitarians, licensed drain-layers, installers, building 

 inspectors, plumbing inspectors, haulers, and all other associated professionals should be 

 reqiured to complete a classroom training course, pass a written exam, and pass a field 

 exam which would demonstrate the qualifications necessary in responsibly dealing with 

 these systems. Consider requiring confirmation certification for professionals having 

 grandfathered rights. For training of private sector professionals, training program costs 

 should be supported by professional associations, and by license fees. For training of state 

 and local program staff, costs should be allocated among the state and towns. 



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