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Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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9/25/20  3:27 pm
Commenter: Terry Sopher Sr

Yes PERMANENT regs but update to reflect latest science expertise re C19

I commend VA for planning to make permanent regulations and guidance.  This is vital to recover the economy, stabilize businesses and resume effective education.  Failing to institute effective management & control of C19 will result in more extended disruption of economy, more failure of businesses, & extended deprivation of income & education. Those who oppose govmt action like these proposed regulations, do not understand that FAILURE to do so will result in more economic disruption, business bankruptcy and job & income losses.

IMPROVE the regulations & guidance to be fully consistent with the very latest Covid research results that provide guidance on how to more effectively manage & end the C19 pandemic in USA.  I refer you to the National Academies of Sciences Aug.26-27, 2020, workshop: "Airborne Transmission of SARS-CoV-2" The latest research confirms airborne transmission is a significant transmission source that must be properly managed if we are to end the pandemic & its disruption of economy, business, education, and community life. [see link: Airborne Transmission of SARS-CoV-2 ].

Consistent with this latest medical science/research, [AND encourage more rapid recovery of VA businesses, economy, jobs, education, health infrastructure & personnel; & to prevent further loss of lives, health, livlihoods], I recommend you add an introductory section of the regs/guidance that is worded something like the following: 

"Our goal is to minimize transmission of C19 in order to protect citizens' health, prevent deaths, and minimize further disruption of the VA economy, businesses, jobs, education, & livlihoods.  Synthesis of the latest scientific/medical research emphasizes 2 key points: (1) NO SINGLE STEP by itself will be effective in controlling C19; (2) C19's human toll & disruption of economy/business/jobs/livlihoods can best be achieved with a combination of simultaneous steps. That combination of steps includes the following: (1) universal mask wearing indoors; (2) minimum physical distancing of 6 ft., even while wearing masks; (3) effective cleaning & disinfection of surfaces; (4) indoor air filtration to at least MERV 13 level; (5) higher than normal indoor ventilation rates providing at least 6 air changes per hour to dilute any indoor air concentrations of infectious virus particles.  Consistent with this scientific guidance, VA's intent is to be a leader in promoting the adoption & practice of this combination of approaches to achieve maximum & timely protection of Virginian's health and livlihood."

I urge revisions of the proposed regs/guidelines to adopt and reflect the following points that are based on the latest, sound medical/science research on C19 related topics.

1. universal mask wearing indoors is the ONLY effective means of controlling & managing the pandemic given that (a) quick response testing is NOT widely available; (b) it may take 14-21 days for a person to develop symptoms, but they can be infectious from day #1; (c) many people can be either ASYMPTOMATIC or have mild symptoms mistaken for a common cold or flu; (d) it is NOT TRUE THAT A MASK does not protect the wearer from others' viruses; (e) normal breathing, talking, etc emits a large cloud/plume of large & microscopic particles that travel much farther than 6 ft indoors & such cloud can be very infectious if from an infected person.

2. the most effective--& preferred--filter mask/face covering for everyone [nonmedical] is either (a) an N95 NIOSH tested & approved disposable filtering face piece, or (b) an K95 one authorized by FDA & preferably sampl tested by NIOSH.  DIY & many other masks/face coverings seldom are effective at filtering out most virus-sized particles.

3. 16VAC25-220-30 definitions section should be revised to reflect the above referenced latest science info.

4. 16VAC25-220-30 definition of AIIR needs revision to provide the following:  air exhausted outside must NOT occur in the following situations: (1) where the exhausted air will be directed toward areas people occupy or frequent; (2) where exhausted air may cross contaminate the building's ventilation air intake zone.

5. definition of "Disinfectants".  (a) selected EPA-registered disinfectants should AVOID those containing substances known to cause adverse health effects, such as those containing quaternary ammonia that is a known respiratory irritant. (b) This section improperly refers to 'killing' viruses--the correct reference would be to 'neutralizing' or making 'nonviable', given that viruses are technically NOT alive.

6. Face shields: it should be noted that face shields ONLY protect from large wet droplets, but do NOT prevent exposure to the airborne particles that can get to the eyes or be inhaled when the air plume merely goes around the edges of the shield.  Face shields must be combined with filtering face mask to effectively protect the person from inhaling airborne particles.

7. Definition of 'face coverings': based on latest research it is wrong to assert that face coverings are 'not intended to protect the wearer...."


CommentID: 86327