Virginia's working people are in desperate need of a strong, enforceable standard to ensure protections from the coronavirus. I urge the Board to advance these regulations in a timely manner and require employers to implement these life-saving safety standards. 

While the standard is a great step, I suggest four critical improvements to ensure the fullest protection for Virginia's workers from this deadly virus.

1. The Virginia standard must the enforceable standard and the provisions allowing for employers simply comply with the CDC guidance should be removed. This would eliminate selective application of these safety standards. Additionally, the CDC continues to modify the guidelines and do not always prioritize the safety of the employee.
2. The standard must clearly recognize airborne transmission of the virus as well as asymptomatic transmission. The scientific evidence is clear.
3. The risk categories do not take into account the current exposure and infection rates in workplaces. Certain professions require contact with the public and subsequently have a higher risk of disease exposure. The standard must ensure that
   all high-risk workers are all equally protected. Employers should complete exposure assessments, infection plans and conduct training for ALL at-risk workplaces.
4. The standard must include strong requirements for reporting and
   recordkeeping. It is impossible to understand the location and severity of outbreaks without solid documentation and targeted prevention measures.