On behalf of the Virginia Association of Counties (VACo) I offer the following comments regarding the proposed permanent standard: (1) The standard is to protect the health and safety of employees for a disease with currently no available vaccine and limited effective treatment. The entirety of the standard includes numerous requirements that will be unnecessary once the pandemic ends. Given such, and the practical and financial implications associated with this eventuality, VACo recommends consideration be given to incorporating a provision into the permanent standard that suspends the requirements once the spread and impacts of the virus have been limited; (2) The requirements for the implementation of "return to work" procedures are too prescriptive for a situation where testing and monitoring for symptoms of the virus continues to evolve. VACo recommends that counties as employers only be required to adhere to the latest Virginia Department of Health (VDH) guidance that includes a decision tree to use in determining next steps for employees who are sick and may or may not get a COVID test; and (3) The requirement that air handling systems, at a minimum, comply with ANSI/ASHRAE standards 62.1 and 62.2 (ASHRAE 2019a, 2019) is neither technically or financially feasible for our members. Additionally, this 2019 standard has yet to be incorporated in the Virginia Building Code. VACo recommends that the requirement only be that a facility's current air handling system be maintained in accordance with manufacturers instructions.
Thank for you for the opportunity to comment on the proposed standard.
Joe Lerch, VACo Director of Local Government Policy