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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  5:26 pm
Commenter: Virginia Association of Community-Based Providers

Please do not make the emergency temporary standards permanent

The Virginia Association of Community-Based Providers (VACBP) represents small businesses across Virginia that provide behavioral health and substance use disorder treatment to Virginia's most vulnerable residents, including its Medicaid members.  Our members have significant concerns about taking action to make the COVID-19 Workplace Safety Emergency Standard permanent without more thoughtful consideration and engagement by small businesses like those who are members of the VACBP to evaluate the impact on businesses, their employees and those they serve.


Now six months into the pandemic, our members have taken extraordinary measures to adapt to this unprecedented time while ensuring compliance with licensing standards and CDC requirements. They are singularly focused on keeping their employees and those they serve healthy and safe. 

With the current temporary emergency standards in place, there is time to conduct a more thorough review and consider what standards warrant being permanent. Imposing “one size fits all” approach by subjecting COVID-19 regulations on all employers is not prudent without a more thoughtful and inclusive review, especially when guidance is continually changing as we learn more about the virus.


We strongly urge the Board to take the time to determine how best to ensure the safe operation of Virginia businesses and the safety of their employees and, for our members, their patients. Thank you for your consideration of the VACBP's concerns related to this very important manner. 

CommentID: 86436