Agencies | Governor
Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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9/24/20  8:35 pm
Commenter: Lisa Harris

In support
  • The permanent standard is necessary to protect working people in Virginia

    • COVID isn’t going away and there continue to be outbreaks

    • Another wave is likely very soon

    • Without permanent protections, workers will be at risk

    • Airborne transmission requires the strong standard.

    • Needed for all workers - no exceptions

    • A strong permanent standard will be useful for future pandemics

  • Clear standards coming from one agency of authority simplifies things for employers and workers

    • Standard requirements do not change with no notice as federal recommendations have been doing

    • Based off science instead of influence from big business interference or political whims

    • CDC/education exceptions makes it confusing and is impractical for employers - it should be removed

  • The ETS is a strong standard and should be made permanent

    • The standard is effective when employers implement the protections

    • Standard is based off scientific information, long-standing occupational H&S practices, and health & safety recommendations

    • Protections are important for controlling airborne hazards, which SARS-CoV-2 clearly is

    • The standard is a programmatic standard, so instead of being overly prescriptive, each employer is required to implement a program tailored to their workplace using scientific-based and longstanding workplace control practices

    • Highlight importance of key components for all at-risk workers: risk assessment, plan, training, etc.

    • Key components are based off current OSHA standards and familiar to employers and workers

    • Return to work requirements align with current science.

    • Ventilation requirements are in line with industry standards (ASHRAE)

    • Respiratory protection is clearly defined and required for workers who are deemed at risk

    • Face coverings are clearly defined and required according to previous VA mandates and helps control the spread of droplet transmission

  • Recommendations for improvement:

    • Removing CDC exception

    • 6 foot rule is not an effective control for airborne exposure - the virus travels farther. Ventilation, reduced persons and time in spaces, and other controls must be combined with distancing

    • Medical removal for known infections, exposures, or when recommended by a medical or public health professional, with removal protections

      • The employer must maintain the employee's base earnings, seniority, and other rights and benefits that existed at the time of removal until cleared for return to work

    • Strengthen the involvement of worker/rep involvement in the plan - the language is good, but it happens less often in practice. VOSH should ensure their educational material and enforcement efforts are clear that this must be done.

  • OSHA has a longstanding history of helping employers with compliance and enforcement discretion with employers who are making good faith efforts.

    • A permanent standard is needed to protect all workers, as COVID isn’t going away and will help protect workers from future pandemics

    • The ETS is a strong, comprehensive standard that sets clear requirements based off longstanding practices and current science and should be made permanent

    • VA should move forward with the permanent standard rule-making with haste in order to ensure all workers are protected from COVID permanently

CommentID: 85974