June 21, 2020
Ms. Princy Doss
Director of Policy, Planning and Public Information
Virginia Department of Labor and Industry
600 East Main Street, Suite 207
Richmond, VA 23219
RE: 16 VAC 25-220, Emergency Temporary Standard/ Emergency Regulation Infectious Disease Prevention SARS-CoV-2 Virus that Causes COVID-19
Ms. Doss:
On behalf of the Virginia Restaurant, Lodging & Travel Association, we want to take this opportunity to share our organization’s comments regarding, the emergency temporary standard and emergency regulation for preventing COVID-19 in places of employment.
Hospitality and tourism related businesses have been diligently complying with COVID-19 related requirements from the Governor’s Executive Orders (EO), Virginia Department of Health (VDH), and applicable federal standards. After reviewing the proposed regulations, our organization has many concerns and questions about the standards under review by the Virginia Department of Labor (DOLI) and Industry. Below are our comments:
As noted above, there are many issues with the proposed language in the regulations that appears to conflict with Virginia Department of Health guidelines and Governor Northam’s Executive Orders, and there is significant uncertainty as to many aspects of the Virginia Department of Labor and Industry emergency temporary standards.
We are now three months into the COVID-19 crisis and during this period hospitality and tourism related businesses have put into place policies and procedures pursuant to VDH and EO guidelines. Imposing new standards will create additional financial hardship and loss of economic activity that will further harm Virginia’s economic recovery.
For these reasons, we strongly believe that the best approach is to not promulgate these regulations. Instead, we urge you to enforce and administer VDH, EOs, CDC, and OSHA guidance which provides the means to address the public health issues pertinent to mitigating transmission of COVID-19.
Sincerely,
Eric Terry
President
Virginia Restaurant, Lodging & Travel Association