Valley Proteins, Inc., is the largest privately-owned independent renderer in the United States and is a strategic partner with the poultry industry in Virginia.  We have implemented policies and practices in response to COVID-19 for the protection of our workforce.  These are based on guidance from CDC, OSHA, VDH, and other sources.  Our practices have evolved throughout this crisis and continue to evolve as circumstances change in the workforce and community and as new information becomes available abut COVID-19. 

We oppose the DOLI emergency regulations on that basis that:

This creates a rigid approach to a situation that requires flexibility and adaptation as circumstances change.

These regulations are unnecessary, since employers have guidance from CDC, OSHA, VDH, and others, and are already subject to enforcement action under OSHA.

We have already put effective procedures and policies in place.