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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  10:47 pm
Commenter: Steven Hart, Ph.D, P.E.

Please do not do this to me and my dreams

I have a full time day job teaching Civil Engineering at Virginia Military Institute.  Prior to that I served in the Army for 26 years.  I also have a 150 acre farm I operate with my family.  We have started a farmers market on the farm and hope one day to have a general store, a folk school, and multiple cottage industries.  I am writing this to you at 10:30 pm after an 18 hour day.

I always tell my students to read the assignment before writing, but I can't do that with this rule.  It's FORTY SEVEN pages long.  This type of rule is DEATH to small businesses.  What hours of the day am I supposed to spend reading this thing, much less trying to comply?  Furthermore, it is simply another directive from another unelected bureaucrat imposed on the citizens where our government is telling us "You must comply or else!"  and from which we have no redress.  

My area of teaching and research expertise has been Critical Infrastructure Risk Management and Resilience for 13 years.  In that field we have learned we should " make risk informed decisions.". Risk is a function of consequence, threat, and vulnerability.  The rules we have applied in this situation have made almost no allowance for variations is consequence and vulnerability for populations, circumstances, and local conditions.  They apply concepts like building occupancy, which is an architectural concept to ensure sufficient fire egress, in an arbitrary manner (where is the science behind 50%?) for purposes for which they are not designed or suitable.  They consider only one dimension of a multi-dimension problem.  For every bit of help they might provide, the provide harm in other areas.

CommentID: 86622