Thank you for the opportunity to provide comments on the Commonwealth’s proposal to rescind the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220. On behalf of PRINTING United Alliance, we submit the following comments and suggestions.?? 

 PRINTING United Alliance represents the interests of facilities engaged in the production of products through screen, digital, flexographic, and lithographic printing processes.? This includes facilities engaged in garment decoration, production of membrane switches, decals, all types of signage, as well as paper products, such as books, pamphlets, and other marketing materials.? Our industry is comprised primarily of small businesses, with about 80 percent of establishments employing 20 or fewer people.?? 

We understand the concerns of the Commonwealth regarding the safety of the workforce during this time of pandemic. However, we believe those concerns must be tempered with common sense and recognition of costs that businesses incur to comply with COVID-19 regulations.? 

Collectively, the printing industry supports the proposal to rescind the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220. This support should not be interpreted as opposition of the printing industry to protect the workforce against this or any other infectious disease.? PRINTING United Alliance has a long history of providing safety compliance information to our industry with the goal of reducing workplace injuries and illnesses.? During this, we have and continue to provide up to date information to the industry on state emergency orders, safe work practices based on guidance by both the Center for Disease Control and Prevention (CDC) and state and federal agencies., as well as critical employment information.? Our goal continues to be one of providing information to members of the printing community on safe operation while adhering to guidelines established by federal, state, and local agencies on how to protect its employees from COVID-19 infection.? 

When this rule was first proposed, we submitted comments in opposing adoption as we did not see the need for a formal rulemaking implementing specific safety and health practices for this pandemic.? We found that as more information about the virus became known, the CDC, Occupational Safety and Health Administration, Environmental Protection Agency, Food and Drug Administration, and state/local agencies continuously revised their guidance on how to best protect the public and workers. This changing guidance, issued by the CDC, quickly made certain provisions in initial and subsequent VOSH rule obsolete until the rule was amended to allow businesses to follow CDC guidelines and remain in compliance if those guidelines conflicted with the requirements of the rule. 

We continue to believe that since VOSH has adopted all the relevant federal standards, the agency already has the authority and regulatory oversight to address safety and health issues associated with this pandemic situation and would use that authority to take enforcement action if a company were not following the rule or latest CDC guidance.? Any additional regulation is unnecessary and would impose significant costs on businesses at a time when many cannot afford it due to the circumstances surrounding the pandemic and its effect on workforce and supply chain issues.  

The PRINTING United Alliance remains committed to providing the graphic communications and printing industry with resources to address safety and health issues associated with the COVID-19 pandemic.? However, we do not believe that a formal safety and health regulation is either appropriate or warranted as current general industry standards are comprehensive and sufficient.? ?? 

Thank you for the opportunity to provide our comments on this important regulatory initiative.?