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More issues on the maintenance of onsite systems
Part Three
By Elizabeth Dietzmann
I admit it. This whole topic has gotten away from me. The more I talk to people in the onsite industry, the more confused I get. I last left you with a promise or maybe a threat to pick up the thread and talk about service provider training. That was supposed to be the next logical piece of this puzzle. Remember? I had concluded that it might not matter what kind of O&M tracking system you used, be it the “operations” approach as in “remote monitoring device” or the “maintenance” approach as in the “comprehensive database” approach, if you didn’t have some sort of standardized training for service providers. And there desperately needs to be standards because training and certification for service providers (new acronym: T&C) runs the gamut at the state and local level. It ranges from none at all to simple registration to manufacturer training to advanced training with exams to comprehensive training at every level in states such as North Carolina and Florida.
This was sounding easy. Training for service providers. Everyone agrees that T&C is a good thing. I knew the EPA was busy promoting credentialing and skills certification as one of the key ways to overcome the reluctance of regulators to approve the use of decentralized technology (one of the infamous barriers identified in the EPA’s 1997 Report to Congress). The EPA has been spending money on developing training too. Lots of money. Lots of training. Who would not agree that we must have trained professionals in order for onsite systems to be properly designed, installed, inspected, and maintained? This is where the wicket got sticky for me. Since the NSF first offered its Onsite Wastewater Inspector Accreditation in 2001, the T&C business has exploded. Now there are a plethora of programs. There is training. There is testing. There is training combined with testing. There are parallel programs for installers, inspectors, and service providers. Four of the eight parties to the 2005 EPA Memorandum of Understanding to Advance Decentralized Treatment have training/testing programs of some kind. And more are on the way.
The multiplicity of training/testing available is symbolic of the fragmented nature of the onsite industry. We went from scant regulation, training, and performance standards to so much overlapping training and testing that it makes my head spin, and no doubt the heads of everyone in this business. We can start at the beginning, I guess. As mentioned, the NSF has been offering its Onsite Wastewater Inspector Accreditation since 2001. One hundred multiple-choice questions and a field test. Not for the faint of heart or for anyone but experienced practitioners. As of May 3, 2007, 37 brave souls have passed the test. The NSF doesn’t offer any training—just testing. This is intentional. As I have gleaned from the world of credentialing, this avoids any conflict of interest and any incentive to pass folks just because they pay for training. OK. So far, so good. But the National Association of Wastewater Transporters Inc. (NAWT) also offers a program for septic system inspectors that includes both training and testing. According to the NAWT Web site, “Certified Inspectors must complete a comprehensive onsite sewage treatment systems course covering terminology, treatment, tanks, construction methods, and application, or demonstrate competence in the field prior to qualifying for the inspector training program. Participants then must complete the inspection course and pass a rigorous exam to receive national certification. There are only a selected number of professionals throughout the United States and Canada who have successfully completed both courses.”
In the world of credentialing I am not sure how the final “certification” is different if the entity that administers the exam is the same entity that offers the training, but lots and lots of folks are NAWT certified and a number of states and counties rely on NAWT certification for inspectors. Did anyone notice, however, that the NAWT program covers installation and construction issues as part of inspection training? It looks like there is an intro course on installation that you have to take before you take the inspection course. (Keep that in mind for later.)
From what I can tell, compared to the NSF program, the NAWT’s program is more of an entry-level program. I have heard from folks at the annual Pumper Show that it is unusual not to pass the exam once you have completed the training. Maybe that is good. It encourages newcomers to the world of inspection to get some standardized training, even if the entity giving the test is the same entity collecting money for training. The confusing part for me is that the people taking the NAWT training are by and large already installers or maybe even installers and service providers, who are making a smart business move and adding septic system inspections to their business. But how did they get trained as installers? Virtually every onsite installer I have ever spoken with told me that his/her training was the OJT variety. When you think about it, that makes perfect sense. How else could you learn how to install a system? True, for advanced treatment systems, the manufacturers should—and do—offer training in the installation of their particular technology. But the installer still has to learn the basics on his/her own. And back at the local level, installers may have to register or demonstrate some sort of basic skill set in order to be approved to install systems locally. This is going to vary dramatically from county to county and state to state.
So then comes the National Environmental Health Association (NEHA), the folks who brought us the Registered Environmental Health Specialist/Registered Sanitarian designation, and even though there is no industry installer training available now, they were funded by the EPA to offer an installer credential. I will admit that this was a bit confusing to me. And I was not alone. I sat in a room full of NAWT-certified inspectors in February at the Pumper Show and listened to a presentation on the new NEHA installer credential. Repeatedly, the presenter was asked why they needed another credential if they were NAWT certified and what they were supposed to study for the NEHA exam if there was no installer training offered. In their minds, these guys had already covered installation as part of the inspector training. As one older gentlemen stated, “Heck, I couldn’t even pass the NAWT inspector test if I didn’t know how to install systems!” But wait, there is more. We also have the Consortium of Institutes for Decentralized Wastewater Treatment’s (CIDWT’s) extremely comprehensive O&M training materials that were developed as an outgrowth of the Curriculum project. The CIDWT perfected the O&M material in some pilot training workshops during the last couple of years and then launched its “train the trainer” workshops involving the O&M training materials. If the NAWT completed the “train the trainer” course, then it could take those materials and develop a certification. This is exactly what the NAWT has done. The NAWT now has two two-day classes with a test at the end of each class. This constitutes its O&M certification. According to Kit Rosefield of Accredited Septic Monitoring and a NAWT trainer, the NAWT will require that an individual complete the NAWT inspector program before taking the O&M training.
Is there more? Yes, there is. After the NEHA installer credential was already created, the CIDWT is now working on the development of training materials for installers. Don’t look at me. The EPA chose to fund the development of the exam before there was any training. Yes, the materials are being developed after the NEHA exam was created. The scenario will follow the same model the CIDWT used for O&M training. It will develop the installer materials, perfect them, and offer “train the trainer” classes. Then a group like the NAWT, or any other group who completes the training, can use the materials to develop an installer certification program. The CIDWT is hopefully going to be funded by the EPA via the Water Environment Research Foundation, and it looks like the NAWT will develop an installer certification based on the CIDWT materials. This is all to come in the future. In the interim, however, Onsite Installer Magazine from Cole Publishing, has wanted to offer installer training, so it got some of the folks involved with the development of the NAWT and CIDWT installer materials to develop a one-day installer training to be offered at the Pumper Shows. And as the final touch, NEHA is in the process of submitting a proposal to the EPA, which has funded all of these other programs except for NSF, for a designer/reviewer credential. So soon you can be both an NSF- and NAWT-certified inspector, a NAWT- and NEHA-certified installer, a NAWT-certified O&M provider, and maybe someday a NEHA-certified designer/reviewer. Is anyone else confused? Who has the time and the money to pursue all these certifications and take all this training? And which combination of these tests and training, if any, will local regulators adopt? Is any of this training uniform? More importantly, doesn’t it all cover the same core competencies inherent in all these activities? Where is the thoughtful planning?
Massachusetts Title 5 illustrates this nicely. I missed Tom Grove’s presentation at the National Onsite Wastewater Recycling Association (NOWRA) show in March, but he was kind enough to send me a copy of his paper, “Privatization Case Study: Administration of the State of Massachusetts’s Onsite Wastewater Training and Certification Renewal Program.” As the director of wastewater and onsite programs with the New England Interstate Water Pollution Control Commission, Grove has inherited the Massachusetts Title 5 certification and renewal program for onsite system inspectors and he is wrestling with some of these very issues. I would like to quote from Grove’s paper because it illustrates my point that it is virtually impossible to distinguish many aspects of the roles of designer, installer, inspector, and O&M provider. This is the description of the exam that will be given:
The intent of the examination is “to establish the fitness of the applicant for certification to assess the condition and function of onsite systems and to determine whether maintenance, including repair or replacement of system components, is necessary.”
So who can take this inspector test?
“These additional qualified professionals may consist of Board of Health members or agents, Engineers in Training (EIT), MA licensed home inspectors, associate home inspectors, licensed septage haulers, system installers, or other individuals with at least one year of experience in system design or inspection.”
Installers, designers, and O&M providers can all take the test to become inspectors. That looks like all these jobs are interconnected to the point where it is almost impossible to distinguish between the certain aspects that they all have in common.
Better yet, has anyone ever compared any of the actual training and testing materials to see if there is any overlap there? I had a great conversation with Christl Pokorney of NEHA on this very topic. Just out of curiosity I asked Christl if she had ever heard of the EPA asking NEHA or any other group to compare the different training/tests in order to see what level of duplication existed before funding more certification or training. The answer appears to be no. In fact, just as I finished writing this piece, I read in the winter 2007 issue of On Tap, the National Environmental Services Center (NESC) drinking-water magazine, that NESC had just finished an assessment study on who needs what training. Great, I thought! Maybe they have studied the existing programs I just finished discussing! Maybe my questions are answered and they have compared and contrasted the different training and testing programs. Well, not exactly. What was the conclusion of the study, which ran from 2002 until 2005? Designers, installers, inspectors, and O&M providers need more training and there is a lack of federal regulation for decentralized wastewater, which has led to a variety of regulatory approaches at the state and local levels. Sigh. More preaching to the choir, I am afraid. Did we really need to spend more federal money to determine that? What about some comparison and analysis of the overlap in all these existing programs?
I was still curious to know how the roles of inspector, installer, and O&M provider could be segregated and what entity had decided that these set roles needed separate training. I have asked individuals affiliated with the NAWT, NEHA, NSF, and CIDWT. All of them agree that there is overlap and no big-picture planning in the development of training and testing. No one could tell me how you can inspect an onsite system if you do not know how to install one. No one could tell me how can you determine that a system is operating according to its design capacity if you don’t know how it should have been installed in the first place? No one could tell me how you can perform O&M on a system or repair a malfunction in a system if you don’t know to perform an inspection? No one could tell me how you can install a system if you don’t have some idea of how future inspections and O&M will need to be performed. I have never had the opportunity to review any of the exams or training materials, but I suspect that there must be lots of overlap and duplication. I say this because all the groups I have mentioned above are dedicated and they all strive to do the very best job possible and have all spent lots of time and money (much of it from the EPA) developing training and testing for their various programs.
It is safe to say that all of these programs have merit. That was never the issue. The issue is redundancy and duplication of effort in training and certification in “jobs” that are interconnected by their very natures. I guess I could be cynical and just chalk it up to each group wanting to make money off of its own program or industry groups getting tired of the lack of cooperation from one another. Nonetheless, the overlap is there. It is profound and begs for unification and oversight. Who will and should provide this unification and oversight? When will there be federal standards for decentralized technology? Who will insist that all these groups work together to create a streamlined, tiered series of programs that will bring consistency and unity to the industry and allow beleagured regulators to stand a chance of implementing integrated standards for design, inspection, installation, and O&M? Hmmmm. I wonder if the EPA’s memorandum of understanding could be a starting place. Wasn’t that the whole point of all those signatories working together? We’ll see …
Elizabeth Dieztmann is an attorney for AquaLaw PLC and can be emailed at Elizabeth@aqualaw.com.
OW - September/October 2007 |
