Agencies | Governor
Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
Previous Comment     Next Comment     Back to List of Comments
9/25/20  9:03 am
Commenter: Denise Luc

Strongly Support

i M

I teach in NPS and am very concerned that without the protective standard, children and those they come into contact with will spread the disease impacting all around and our economy . Please weigh the issues carefully remembering that the resulting illnesses and deaths will greatly impact our economy. Many teachers are in the older at risk age range and that will also impact the education that our future generations receive. 


  • 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: 86046