Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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6/22/20  6:45 pm
Commenter: Thomas Calhoun Norfolk Federation of Teachers

Protect all Virginia Workers

Working people are in desperate need of a strong, enforceable standard to require their employers to plan for and protect them from COVID-19.  I urge the board to vote for moving forward on this standard in a timely manner.

Yet, there are four key improvements that must be made to make sure the standard truly protects workers from this deadly virus.

  1. The provision allowing for employers to comply with CDC guidance as a replacement for following the Virginia standard must be removed. Voluntary guidance is never a substitute for an enforceable standard. Also, the CDC has watered down guidance during the pandemic due to industry desires instead of scientific reasoning and public safety.
  2. The standard must clearly recognize 1) airborne transmission of the virus (which requires higher levels of adequate respirators and social distancing), and 2) asymptomatic transmission of the virus (which requires high levels of protection and quick removal from work with paid leave and employer reporting of cases to public health department and OSHA, etc.). The scientific evidence is clear.
  3. The risk categories in the proposal are misguided. They are not relevant to the current exposure and infection rates in workplaces. We now know that all workplaces where workers are in close contact with the public or their coworkers are at high risk of exposure, such as meatpacking and corrections, not just in healthcare settings. The standard must ensure that all high risk workers are protected equally from the virus through requiring an exposure assessment, infection plan, controls, reporting and training in ALL at-risk workplaces.
  4. The standard must include strong requirements for reporting and recordkeeping. These elements are currently weak or missing and are essential to quickly understand the location and severity of outbreaks and to target prevention measures.
CommentID: 83333