Properly trained and certified personnel are critical to ensuring that SSTS are properly designed, installed, and maintained to protect Minnesota lakes, streams, and groundwater, as well as human health.

As many local SSTS program staff approach retirement and a new generation of technicians assume SSTS program responsibilities, the MPCA is receiving questions about what work duties local program staff can and cannot do before becoming certified.

This guidance is intended to answer those questions as well as provide tips for expediting the process of becoming certified.

What are certified employees?

There are many tasks local staff can work on to help their SSTS program before becoming certified, but there are some tasks that must be completed by a “qualified employee” or a “designated certified individual” authorized by the local SSTS program.

  • Qualified employee (QE) is an employee of a governmental unit that conducts SSTS work as a part of their job duties. This person must hold certifications in the specialty areas applicable to the work being conducted. (Minn. R. 7083.1010)
  • Designated certified individual (DCI) is a person who has met specialty area certification requirements and has been designated by a licensed business to comply with program requirements (Minn. R. 7083.0720). Local units of government may authorize a DCI from a licensed inspection business to perform certain tasks in place of a qualified employee (Minn. R. 7083.0750 Subp. 1).

A QE employed by a local unit of government is similar to a DCI for a licensed business — both are terms described in rule that represent the relationship between an individual and either a jurisdiction or a business. It is important to define these relationships and clarify roles and responsibilities to ensure that competent people complete their work in a way that meets program requirements and establishes clear paths for accountability.

The certification process for an individual is identical for a QE and a DCI:

  • complete required training
  • pass certification exams
  • complete an experience plan/apprenticeship, and
  • participate in ongoing continuing education.   

Individuals may be considered a QE or DCI once they become an apprentice, meaning they have completed their required training and passed their exams, but have not yet completed their experience requirement.

However, apprentices may only operate under the direct supervision of their mentor until their certification application has been approved by the MPCA. Once that happens, they are allowed to independently conduct tasks that require certification on behalf of the local program and independently sign certified statements, which are signatures used to attest the licensed business or qualified employee completed work in accordance with applicable requirements.

Work tasks that can be performed by non-certified employees

Most new SSTS staff have a lot to learn about the SSTS program before they can exercise the discretion necessary to effectively perform their role as local government employees. Here are five suggested SSTS work activities that can be conducted by individuals that have not yet earned their certification as an SSTS inspector.

Create a learning plan and timeline

The SSTS Certification and Licensing QuickTool provides a customized plan for obtaining the required training and the steps to obtain a certification.

Experience and apprenticeship

Non-certified employees that are working towards becoming QEs should job shadow the current QE or DCI as often as possible to gain supervised, practical experience conducting the technical tasks that require certification to complete.

  • Identify one or more mentors to oversee your experience plan/apprenticeship.
  • Complete tasks that require certification under the direct supervision of an eligible mentor or other qualified employee.
  • Connect with practicing professionals in the area and observe their work and learn from their experiences.
  • Document your experience and observations as you go, and submit with your certification application once you complete the required training and exams.

Learning and training

Staff can read, practice, and learn about SSTS work and spend time becoming familiar with the SSTS program, state statutes, rules, guidance, and tools.

MPCA guidance and information

Statutes and rules

Training, exam preparation, and tools

Document processing and recordkeeping

Learn about the workflow, practices, and expectations of program operations in your jurisdiction.

Communication with professionals and property owners

Prepare correspondence, conduct outreach, gather information, respond to inquiries, and deliver information. New staff can perform supporting roles to ensure permits are issued, inspections are scheduled, and everyone has the information they need when planning projects.

  • Staff can help ensure that all SSTS work is completed by appropriately certified individuals and licensed businesses by referencing the SSTS Search Tool.

Job “shadowing” encouraged, may count toward experience requirements

Before obtaining their SSTS certification, new staff can and should spend time completing tasks that do require certification under the watchful eye of more experienced staff or contractors. Many don’t realize that early job shadowing may also count towards one’s experience requirement. In order for this job shadowing to be counted towards the certification experience requirement, the person performing the oversight role must be eligible to be a mentor and the individual must correctly apply for certification and document this experience. Specific guidance on meeting experience requirements before taking the required training and exams is found in the last section of this document.

Work tasks that can only be performed by someone who is certified (QE or DCI)

Local units of government have a responsibility under state rule and their ordinance to hire staff (or authorize a licensed inspection business) to conduct these specific activities:

  1. Review permit applications and determine if a proposed system is designed accurately and will meet applicable requirements. (7082.0500 Subp. 3 & 7083.0730)
  2. Perform the infield verification of the proposed system’s limiting condition. (7082.0500 Subp 3)
  3. Conduct construction inspections for all new construction and replacement systems. (7082.0700 Subp. 2)
  4. Conduct necessary procedures to assess system compliance. (7083.0750 Subp. 3)
  5. Sign certified statements and award certificates of compliance or notices of noncompliance. (7082.0700 Subp. 2 & 7083.0730)
  6. Any other specialty area tasks that require certification performed by the local program: design, install, service, or maintenance (7083.1010)
  7. Some local SSTS programs conduct existing system compliance inspections or rely on local staff to provide an opinion on disagreements between licensed businesses about the depth of periodically saturated soil. These tasks may also only be completed by a QE. (7082.0700 subp. 5)

Non-certified individuals cannot independently conduct activities 1-7 listed above on behalf of a local jurisdiction. Allowing non-certified individuals to conduct this work creates liability and undermines the integrity of the SSTS program. Local governments, especially those that administer smaller SSTS programs, should develop contingency plans and practice succession planning to minimize the challenges associated with helping new employees become qualified.

The MPCA also understands that circumstances may arise that leave the jurisdiction temporarily without a QE. The MPCA’s guidance to local programs whose only SSTS staff person is in the process of becoming certified is to contract with another local program or licensed business to perform and supervise the tasks that must be completed by a QE.

Experience counts

Working on experience requirements before taking required training/exams can help staff become certified sooner

A non-certified “worker” or employee for a local unit of government may obtain their experience prior to, or in the midst of, meeting their training and testing requirements. The guidance below may help employees expedite the certification process.

  • You may obtain your required experience as an employee of a local unit of government before officially becoming an Apprentice Inspector. The experience requirement for an aspiring QE includes completing with their mentor the design review, infield verification of limiting condition, and new system inspection for 15 systems. While you cannot submit your experience documentation until you have met the training and exam requirements, any experience gained up to six years before your certification application may be considered.
  • After you complete your required training and pass your exams, you should co-submit your certification application and experience documentation reporting paperwork. The only risk to obtaining your experience in this manner is that your mentor is not approved until you submit your certification application. As long as your mentor is certified in the specialty area you are seeking and has not had a violation that has resulted in a successful enforcement action within five years, your mentor will be approved and your co-submitted certification application and experience reporting documentation will be reviewed. If that passes muster, you will skip the “apprentice” phase, and move directly from “employee” to “qualified employee” (QE) status.

Important: You are not authorized to fulfill duties as a QE until you have a certification. Until then work must be done under the direct supervision of your mentor. Any work completed by you without your mentor’s supervision would be considered invalid and a violation of Chapter 7083.1010 and 7083.2010 Subp. 1.  

Current certification application and experience reporting requirements:

While following the guidance just described doesn’t allow local SSTS program workers to act as a QE or independently fulfill the activities 1-7 identified above, it does provide some overlap of the activities required to become a QE and may compress the time it takes to go from hired worker to QE.

In short, employees may expedite their certification process and reduce the time it takes to become fully certified by developing a learning plan and documenting job shadowing activities they can participate in even before taking their first training workshop or certification exam.