Good day - I am writing to you as a practicing Environmental, Health and Safety Professional regarding 16VAC25-220-70 Infectious Disease Preparedness and Response Plan which is a component of the Final Permanent Standard (FPS) 16VAC25-220;
Please consider requiring affected employers to maintain an Infectious Disease Preparedness and Response Plan so when new and emerging threats to the health of the workforce arise - the employer has a solid Plan from which to refer, and operate. Many organizations had Plans for H1N1 (swine flu), MERS, SARS, H5N1 (avian flu), etc and some of those historical Plans were 'dusted off' and revised to form the necessary Infections Disease Preparedness and Response Plan COVID19 required from us.
This type of a working Plan should be maintained by responsible employers as a resource that addresses the organic or standard measures employers and employees should remain aware of. It will help to identify, address, and respond to health threats in their individual workplaces and should remain a living document that adapts or scales either up or down as needed to manage each unique situation.
I request that you consider continuing this requirement for employers to have a written Plan (not unlike those for Respiratory Protection or Hearing Conservation) and maintain it as needed for their industry and assessed risk of exposure. Due to COVID19, this Plan should already be incorporated into most large workplaces currently. It would simply (now) require a review to make it more applicable across the various health threats (some noted above) as well as help to mitigate the more common or seasonal viral impacts (e.g., Cold, Influenza, Gastroenteritis, Strep Throat, etc).
The standard practices for mitigation and response are very similar across many pathogens.
Thank you for all you've done to help protect the workforce (and their families indirectly) during the past two years of this Novel and rapidly changing situation. Nobody could have known the full impact of this Virus, and nobody had a clear playbook with all the answers.
We have learned a lot from this Virus, and I hope we can keep the focus on prevention and mitigation now, by capturing good practices as lessons-learned while documenting them for a value-added tool or resource from which to refer when this happens again.