After reading and reviewing the Revised Proposed Permanent Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus that causes COVID-19 (16VAC25-220) I stand in strong opposition to its adoption.  I offer the following comments and observations as specific examples of my opposition.

1. The permanent standard has no mechanism for ending these requirements.  With vaccines now becoming available a permanent standard is unnecessary.  It would be more sensible to simply extend the temporary standard in reasonable intervals to react appropriately to the changing situation.
2. The reporting requirements place an undue burden on employers and have vague outlines.  The 24-hour reporting requirement does not define a period in which the 2 identified employees were found to be sick, i.e., if employee A is found to have been exposed to COVID-19 on February 1^st and employee B is found to have been exposed on May 15^th, does the employer still have to report to the VDH under this requirement?
3. The reporting requirements create a health risk for employees.  Under these requirements it is a reasonable assumption that some employees will be less likely to tell their employer that they have symptoms or have been exposed to COVID-19 since they will be out of work for a minimum of 10 days.
4. The scientific data does not support that there is an immediate danger to employees categorized as low and medium risk.  Workers such as those in the construction industry who work outside in unconfined spaces, do not interact with the public, and often work alone on individual pieces of equipment.  This type of employee represents a wide portion of Virginias work force and should not be subjected to the same requirements as those employees who must meet at interact with the public daily.
5. As a Professional Engineer working in the construction industry, I have found that the current CDC and OSHA guidelines are more than sufficient regulations for my industry.

Thank you for the opportunity to comment.

Sincerely,

Daniel T. Rickmond, P.E.

Director of Engineering

Bruce Howard Contracting, Inc.