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Central Issues

February 1, 2013

Key Issues of the Environmental Health Registration Board
Central Issues highlights key issues the Oregon Health Licensing Agency (OHLA) is addressing in collaboration with the multiple health and related boards the agency oversees.  In this issue, Central Issues looks at the latest news from the Environmental Health Registration Board.
Three Questions for:  Board Chair Jeff Freund

Q:  How do you see your role as board chair?

A:  Besides keeping board meetings in order, focused, and moving along productively, I think my role as board chair is to fully understand the role of the board as a whole and how it functions within the framework of the Health Licensing Office (HLO).  Beyond that, my role is to work closely with the HLO director and staff to ensure we're all on the same page on the issues, even if there may be differing views among individual board members. 


Q:  What do you think the role of the board is?

A:  To provide profession-specific knowledge and expertise as well as a public member perspective to HOL staff.  We really are a team that combines our knowledge of the profession with our understanding of the regulatory framework within which we work.  We, as board members, need to understand that we have been appointed to serve the public interest first and foremost, rather than the goals of our profession's association. However, that doesn't mean we can't work collaboratively with our professional associations and other stakeholder groups on issues of common interest.  But we have to remember that public protection interests come first. We also strive to maintain a high level of competency amongst EHS practitioners and ensure onging professional integrity.


Q:  How do you see HLO's role in working with the board?

A:  We keep the board on track by reminding us of our role as a board, which is public protection first, that we are not acting as a professional association.  I see the agency's role as understanding issues in our profession enough to know which issues are ones to pursue and which ones are better acted upon by the associations or professional groups.  We provide overall oversight and administration for everything the board may address, from our budget to rulemaking and legislation. 

Problems with Pathway 3B?  Board Examines Possible Solutions


Recently, an applicant with a master's degree in food science and who had taken 45 quarter hours in approved science courses was denied registration.  Why?

Because the master's degree was not in public or community health.

"Unfortunately, as the statute currently stands, the applicant did not meet the qualifications for registration," says Sylvie McMillan, Licensing Manager for the Health Licensing Office (HLO).

Under Oregon Revised Statute 700.030, applicants with a bachelor's degree that includes 45 quarter hours of science courses qualify for registration if they also have two years of supervised experience in environmental sanitation.

Applicants with a master's degree in public or community health qualify for registration if they also have one year of supervised experience in environmental sanitation.

The statutory requirements are repeated and referenced in Oregon Administrative Rule (OAR), specifically OAR 338-010-0015 (3)(c) Registration Pathway 3(B).

McMillan explains that because the requirement is in statute, it would take legislative action to change.

"What sometimes confuses applicants is that the 45 quarter hours in science courses apply only to Pathway A, which is required for applicants with a bachelor's degree, not a master's degree," says McMillan.

Board members voiced concern that as the statute stands, it could be an unnecessary barrier to applicants who may not have advanced degrees in public or community health but who have obtained degrees in more specific areas of expertise that could be considered appropriate for work in the environmental health field, such as food science.

While it's too late for the board to pursue any changes to the statute in this year's session of the Oregon State Legislature, which officially convenes on February 4, McMillian says that the state association or other professional groups could do so.

"We're definitely willing to work with our stakeholder groups to assist them with the legislative process, but the window has passed for the agency to propose such legislation at this time," McMillan says.

Efficiency Task Force:  Can Technicians Perform Limited Duties?

A statewide task force is considering a recommendation to
allow lower-level environmental health professionals to perform limited duties in the Department of Environmental Quality's Onsite Septic System Program.

HLO Policy Analyst Randy Harnisch reported to the board at its November 2 meeting that the Government Efficiency Taskforce Natural Resources Subcommittee may propose legislation to allow environmental health technicians, who are not regulated by the State of Oregon, to perform less-technical work in reviewing onsite septic systems, such as pre-cover inspections and authorization notices.

At issue:  whether or not there are enough registered environmental health specialists and waste water specialists to perform the work, much of which is in rural areas without registered professionals.  Board 2012 Vice-Chair Holly Skogley also voiced concern over whether or not lower-level professionals would be able to see the "bigger picture," potentially having an adverse effect on inspection results.

The board further discussed the issues involved in the proposal during its January 11, 2013, meeting, including the legislative concept related to the proposal, Legislative Concept 1833.

Harnisch stated that HLO would be following any related legislation on the issue and report back to the board.  Harnisch stressed that HLO and the board would remain neutral on any legislation that is brought forward by the Oregon Legislature.  However, the agency would provide the Legislature with feedback on issues related to how to implement any new program.

Board Reviews, Updates Waste Water Specialist Examination

After two years of reviewing more than 400 questions and deleting or revising many of those questions, the Environmental Health Registration Board has approved revisions to the waste water written examination.

The board's Education and Examination Committee met several times over the past two years to review the waste water written examination, which had not been reviewed since its implementation in 1996.

The committee reviewed the more than 400 questions in the examination item bank, covering five domains:  environmental applications, hydrology, microbiology toxicology, regulatory issues, and soils.

After reviewing the entire item bank, the committee determined that the following changes needed to be made to the examination questions:

  • Environmental Applications:  10 deleted and 30 rewritten
  • Hydrology:  four deleted and 14 rewritten
  • Microbiology/Toxicology:  five rewritten
  • Regulatory Issues:  one deleted and 18 rewritten
  • Soils:  23 deleted and 16 rewritten

The committee also streamlined the references used to source the examination from 21 primary and secondary references to 11 primary references.

The examination will continue to consist of 150 questions and a 68-percent mininum passing score will continue to be required.  However, the board removed the three-hour time limit and separated the examination into two segments in the morning and afternoon.

Waste Water Specialist Examination Blueprint and Source Materials

Interested in Serving on the Board?  Three Spots Open
The Environmental Health Registration Board has the following opportunities to serve on the board.  Applicants are encouraged to complete an interest form and submit it to the Governor's Office of Executive Appointments:
  • Public member
  • Physician member
  • Food or food/alcohol beverage retail industry representative
For more information, contact the Governor's Office of Executive Appointments or the Health Licensing Office. 
Click here to download an application / interest form from the Governor's Office of Executive Appointments.

Governor's Office of Executive Appointments 

Contact an HLO board specialist at 503-378-8667 or hlo.info@state.or.us.
By the Numbers

(June 1, 2011 to January 11, 2013)

Environmental health specialists (as of 1/11/13) 244
Environmental health trainees 19
Waste water specialists 9
Waste water trainees 1
New environmental health specialist registrations issued 11
New waste water specialist registrations issued 2​
New EHS trainee registrations issued 11​
New WWS trainee registrations issued 1​
​EHS registration renewals processed 171​
WWS registration renewals processed 4​
Online registration renewals
Environmental health specialist examinations (trainees) 22
Written examination 4
Budget Overview
Ending cash balance (actual 12/31/12) $-19,262.19
Ending cash balance (projected through 6/30/13) $-9,644.44
News You Can Use

Visit www.oregon.gov/OHLA/EHS to find the latest licensing and regulatory resources:


Holly Mercer Appointed OHLA Interim Director


Board Members (including biographies) 

Board Meetings & Minutes

Continuing Education Requirements

Related Websites of Interest

Subscribe to Licensing Line, HLO's e-mail news update

Highlighting Key Issues of HLO Boards

Central Issues focuses on key issues of the volunteer citizen boards HLO oversees.

Comments, questions and suggestions are encouraged.  Contact HLO Public Information Officer at kraig.bohot@state.or.us or call 503-373-1939.

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