On behalf of our Chamber Board of Directors and entire membership, I appreciate the opoprtunity to speak to the proposed Permanent Standard for COVID for ID Prevention: SARS-CoV-2 Virus that causes COVID-19, 16VAC25-220. We have recevied numerous calls and emails of outreach from our membership who share grave concern for the overly burdensome proposal to move the temporary standards for safety protocols to a permanent status. We feel that this consideration is an overreach of the current status that will create an undue and unneccessary regulatory nightmare for businesses. Our businesses have been compliant with the best information available from healthcare and scientific experts at present. We do not know what lies ahead with regard to new and innovative approaches to this virus, and urge you to be cautious and conservative when making decisions (in perpetuity) without all of the information yet known or developed. By making these standards permanent we are ignoring the potential for changing science and thus more flexibility and opportunity for our already struggling businesses to remain both safe and productive. This regulation should sunset at the expriation of Governor Northam's Executive Order as stipulated in the Emergency Temporary Standard (ETS). Again, making this permanent at this time is making a decision without all of the pertinent and ciritcal information needed for a good decision.
Businesses have worked for four and a half months under CDC and OSHA guidelines before the ETS became effective July 27, 2020. During those months businesses implemented critical safety measures to ensure the health of their employees. The guidelines are working and quite frankly additional regulations are duplicative and unnecessary.
The cost of continued required training is yet another burden to already struggling businesses and the hours associated with the training takes time away from other necessary work loads and duties.
We strongly urge you to listen to the business community and place value on their experiences shared with you. They are your stakeholders, along with their employees and families. Good policy making and decision making should always include the stakeholders interest. Therefore, we implore you to reconsider adoption of a permanent standard and instead allow the ETS to remain as previously adopted and direct regulators to work with stakeholders to address concerns in the ETS.
The Emergency Standards are burdensome, obsolete, difficult to enforce, costly in time and money, and lack flexibility to adapt to current science and innovation. We are strongly opposed to the adoption of these as a Permanent Standard for what is a temporary health situation.
Thank you, in advance, for your consideration and the opportunity to provide input.