Thank you for the opportunity to comment on the Emergency Temporary Standard/Emergency Regulation. As critical infrastructure, Alexandria Renew Enterprises cannot stop providing our wastewater treatment and interception services during the pandemic. All of AlexRenew’s staff is considered essential and must be able to continue to report to the campus in order to maintain and operate the wastewater infrastructure for our community.

We support the development of standards to control, prevent and mitigate the spread of COVID-19 in workplaces in the Commonwealth. However, standards must be based on sound science and should allow for flexibility as we learn more about how the SARS-CoV-2 virus is spread. In addition, standards should not overburden workplaces as they work to implement common sense protocols to provide a healthy and hygienic environment.

We would like to suggest that VOSH consider deleting the certification requirements for the workplace hazard assessment. The certification requirement will require that workplaces who already have developed new COVID-19 procedures and protocols that are in compliance with the proposed standard contract with professional services to review and certify the workplace hazard assessment. The funds and time that this would take are better invested in supplies and services to ensure a healthy workplace. This is especially burdensome for organizations like ours that are dealing with reduced revenues due to the pandemic.

If you are unable to delete the certification requirement, please consider explicitly stating that self-certification of compliance with the standards is sufficient. This self-certification should allow employers to certify that they have reviewed the standard and are following best practice recommendations.

Thank you for the consideration of our comments. If you have any questions, please do not hesitate to contact me.