On behalf of the Virginia Golf Course Superintendents Association (VGCSA), I write in response to 16VAC25-220, Revised Proposed Permanent Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19. Our member golf course superintendents professionally maintain green spaces across the Commonwealth that provide recreation and wildlife habitats. Golf is also a significant driver of tourism, with the sport accounting for $2.5 billion in positive economic impact in Virginia. 

We believe making these standards permanent is unnecessary, as most industries have already worked diligently to comply with the emergency temporary standard (ETS) established in July, and have implemented additional best practices and guidance from the Centers for Disease Control (CDC), the Occupational Safety and Health Administration (OSHA), as well as national trade groups.

Golf has provided a much-needed outlet during the pandemic, with the average golf course providing 150 acres of open land, which allows for socially distant recreation. Most courses have fortunately remained open in Virginia throughout the year, and have enjoyed strong player participation. In order to sustain these venues safely, golf course superintendents have utilized tactics and best practices from the Golf Course Superintendents Association of America (GCSAA), which are based upon CDC and OSHA guidance, and are then applied to the tasks required for golf course maintenance. Several examples of changes instituted to keep workers safe include limiting the sharing of tools (or sanitizing tools between uses when sharing is necessary), allowing one employee per golf cart, and removing touchable surfaces such as bunker rakes and water coolers.

The proposed permanent standard does not include an end date. Thankfully, vaccine distribution is occurring and those most at risk are starting to receive inoculation. We fully understand that it will be some time before the majority of Americans are treated, but it is clear we are getting closer to that goal each day. As such, we believe it is critical to include an end date for this standard. As written currently, the proposed permanent standard would require a meeting of the Virginia Safety and Health Codes Board to determine whether there is a continued need for the standard. Providing employers with more certainty as vaccination ramps up would be a better path forward. We know much more about the virus than we did when the ETS was developed, and now have several vaccines approved.

We are fortunate that this situation is temporary. While every industry in the Commonwealth has found ways to adjust to the challenges the pandemic has created, we have largely risen to those challenges. Some proponents have suggested that this standard should apply to other infectious diseases. We strongly believe that any standard that is adopted should focus solely on COVID-19. We cannot begin to assume what protocols may be necessary for any future infectious diseases, so if the Board is going to create a permanent standard, it should be limited in scope.