Since day one with the COVID-19 pandemic Commercial Construction was considered part of the "Essential Worker" classification. This alone put the onus on responsible employers and employees to take pro active steps to stay safe and healthy. With this pandemic being "fluid" many of us have relied on the CDC and OSHA for daily / weekly guidance. Not all Industries face the same challenges and in the Construction world all jobsites do not face the same challenges.  We have put Site Action Plans into effect on all of our projects and our employees have been most supportive of the additional requirements / PPE related to COVID-19. Based on my understanding of the proposed regulation it is not consistent with CDC and OSHA in several areas as pointed out by many of the organizations which you are receiving comments from. I respectfully request that this regulation be tabled until such time that it can be properly vetted by the industries it will affect. 

As Immediate Past State Chairman for the Associated General Contractors of Virginia I would be glad to offer further insight to DOLI. 

Thank you,

Bruce Tibbetts