Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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6/17/20  7:15 pm
Commenter: Eric Bonetti

Suggestion: Clarify Worker-Provided PPE Provisions

I support these standards and believe they will promote worker safety and safe workplaces.

My suggestion is to clarify the worker-provided personal protective equipment (PPE) provisions. As currently worded, employees are protected who provide their own gloves, face shields, masks or other PPE if such equipment is not provided by the employer. 

This creates the risk that an employer may provide low-grade face masks, then prohibit employees who wish to wear an N95 mask or true respirator from doing so, for fear that higher levels of protection may be unsightly or create anxiety on the part of customers.

My suggestion is to require all employers to provide face masks, face shields, and gloves, but to protect employees who wish to provide higher levels of PPE at their own expense.  Thus, if the employee believes that employer-provided equipment is inadequate, or does not address the employee’s risk level due to age or pre-existing condition, the employee may adopt more vigorous safety measures.

Thank you for your efforts in this essential rule-making.

CommentID: 80353