To Whom It May Concern:

Farmworker Justice (FJ) submits these comments in support of the Emergency Temporary Standard/Emergency Regulation 16 VAC 25-220. Farmworker Justice is a national advocacy organization that works with migrant and community health centers, legal services organizations, farmworker community-based organizations, and advocates to improve farmworker living and working conditions and access to healthcare.

We urge you to vote in favor of the Emergency Temporary Standard for COVID-19. FJ has been working with advocates in Virginia and across the country to ensure that farmworkers and other essential workers are able to remain healthy during the COVID-19 pandemic. Workers across the Commonwealth, including farmworkers, need enforceable protections that follow CDC guidance (including information about COVID-19 and the availability of sick leave, access to handwashing facilities, and the provision of appropriate PPE) for their own health and the public health at large during this pandemic and beyond.

Farmworkers, as essential workers, are at the front lines of the COVID-19 pandemic, risking their own health and safety to ensure continuity in the nation’s supply of fruits and vegetables. Farmworkers often work in close proximity, have limited access to handwashing stations and sanitation supplies, are transported to farms in shared vehicles, and live in crowded and substandard housing. With little control over their working conditions, it is imperative that employers are required to implement protections and controls to keep workers healthy and prevent COVID-19 outbreaks.

Keeping Virginia’s workers healthy should be everyone’s priority. Absent any federal regulations by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA), the standards outlined in the Emergency Temporary Standard are essential to ensure the health and safety of Virginia’s essential workers, especially farmworkers. We request that you pass these standards, without hesitation, to prevent further damage to the health of workers and the public during the COVID-19 emergency.

Thank you for the opportunity to comment.

Alexis Guild

Director of Health Policy and Programs

Farmworker Justice