Mr Cristiani,

I oppose this proposal on the following grounds noted in the DPB Economic Impact Analysis.

I must first state, I applaud any effort to ensure the safety of the human workforce. As a veteran of high-risk work environments, I appreciate the scale of responsibility public managers must assume for the welfare of their employees and of those that author and enforce safety regulations. The language of the proposed rule appears to originate from good intentions (and I have no doubt it does). But I fear the only penalties that would be felt are with those small agencies and municipalities who can ill-afford pre-determined monetary penalties in lieu of penalties in the form of percentages relative to a portion of a select budget of the violator.

I would also send caution of the culture that may be created from this policy. The adage “what gets inspected, gets done” may create a culture whereby specific violations are ignored in favor of those identified.

My final concern is that agency departments with large, geographically separated departments (i.e. VDOT, public universities, etc) would be penalized for remote violations occurring outside their department. And how might municipalities respond after large penalties are assessed? Are citizens expected to pay more taxes because of a public managers negligence? Are there laws that would prevent increased fees and taxes after such penalties?

Thank you for your time and service.