Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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6/22/20  9:57 pm
Commenter: Nathan Carroll, Bedford Regional Water Authority

Suggested Revisions to Proposed COVID-19 Emergency Standard/Regulation

Please provide clarification to the definition of "feasible." The definition as stated is too vague to be clear as to what constitutes technical and economic feasibility. 

Do the written certifications listed in the standard need to be submitted to VOSH or any other regulatory agency?

Personally-provided PPE needs to be restricted to a respirator, face mask, face shield, or gloves; please strike “including but not limited to” from the sentence related to this on page 35. Leaving this open to interpretation may put employers in a position where they must tolerate unreasonable uses of items that are not PPE and create a distraction in the workplace.

In general, the standard is entirely too stringent relative to the number of cases in our area and the level of precautions in place up to this time that have successfully mitigated the spread of the disease. If there must be an emergency standard in place at this time, it should be a tiered standard that takes into account number of cases and local population density in addition to worker classification.

CommentID: 83633