1) Page 6 – Section -20 Dates: [Under 40.1-22(6) This emergency temporary standard shall expire within six months.

Recommendation: The emergency temporary should be extended for one year instead of the six months. This will give industries ample time to implement emergency standard in the workplace effectively.

(2) Page 11 –  Item 1. “Medium” exposure risk hazards or job tasks may include, but are not limited to operations, and services.

Recommendation:    I would suggest adding the following to “high risk” category such as, contact tracers, postal workers, meatpacking workers at poultry, seafood processing plant, farmers (who pick the fruits and vegetables), public transportation, fast food workers, airline industries, gig workers, grocery stores, correctional facilities, jails, detention centers, educators for both public and private school and daycare centers. They are our front-line and essential personnel required to work during this pandemic.

(3) Page 16 – Section - Mandatory requirements for all employers.

Recommendation: Employers must engage in case reporting to trace and track using database management system of negative test results and report results to local, county and state health department.