Virginia Regulatory Town Hall
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Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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1/8/21  2:01 pm
Commenter: Philip F. Abraham, Old Dominion Highway Contractors Association

Opposition to Proposed Permanent Standard
 

On behalf of the Old Dominion Highway Contractors Association (ODHCA), I am writing to express opposition to the proposed Permanent Standard for Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220.  ODHCA represents highway contractors from across the Commonwealth.  Our workers are our most important resource and our members have made worker safety a top priority during the COVID-19 crisis while we continue to meet the infrastructure needs of the Commonwealth.  Our members are particularly concerned that the proposed permanent standard has no specified end date and is based on a temporary standard for a temporary health crisis for which there are now 2 vaccines distributed to Virginia with over 90% efficacy and several more candidates are nearing the end of their trials.  It makes no sense to continue indefinitely a standard that was adopted to respond to a specific disease, COVID-19.  Continuing these standards after the pandemic has been contained and the Executive Order is lifted will impose unnecessary burdens on both businesses and their employees for little if any health benefit.  If you proceed to make the standards permanent, please make sure to include a specific sunset date tied to the control of the virus and the lifting of the Governor's Executive Order.  Thank you for consideration of these comments.

CommentID: 88987