We believe there are four key concerns the agency needs to address:

The provision allowing for employers to comply with CDC guidance as a replacement for following the Virginia standard must be removed. Voluntary guidance is never a substitute for an enforceable standard. 

The Standard should clearly recognize the airborne transmission of the virus and the asymptomatic transmission of the virus; and, the additional required precautions.

The Standard must ensure that all high risk workers are protected equally from the virus through requiring an exposure assessment, infection plan, controls, reporting from and training in all at-risk workplaces. This is especially needed in retail locations, food preparation and food serving businesses, correctional facilities, educational entities, and all personal contact industries.

The Standard must include strong requirements for reporting and record keeping. These elements are currently weak and/or missing all together; and are essential to quickly understand the location and severity of outbreaks and to target containment.