Mr. Crisanti,

In response to the proposed regulation to amend the administrative regulation for the Virginia Occupational Safety and Health (VOSH) Program; State and Local Government Penalties, I am in favor of this amendment.  My reasoning stems from the simplicity of the amendment to include penalties on only infractions that have been repeated or are considered "high gravity".  State and local governments should be taking appropriate precautions to prevent the occurrence of these infractions.  Unfortunately, one cannot depend on an agreement of correction without some stipulation attached to it.  State and local governments are held to the same principles as private organizations.  In some cases, they should be held to higher principles due to their relationship with the public that they serve.  In any case, all organizations should be held accountable for not adhering to safety regulations and protocols.  Repeated offenses must be rectified and serious infractions dealt with in an appropriate manner.  If that means fines have to be imposed, than do what must be done to ensure compliance.  My only recommendation would be to create a separate fund that these funds are placed into so that the money can be appropriated to help disadvantaged workers who cannot afford the medical bills associated with a "high gravity" injury.  If they were injured as a result of the state or local government failing to adequately secure a safe working environment, then they should not have to bear the brunt of the expenses.

Thank you for your time and consideration of my recommendation.