AFFILIATE OF NATIONAL SOCIETY OF PROFESSIONAL SURVEYORS
10340 DEMOCRACY LANE, SUITE 300
FAIRFAX, VA 22030
844-414-1466
info@vasurveyors.org
September 25, 2020
Safety and Health Codes Board
Department of Labor & Industry
600 East Main Street, Suite 207
Richmond, Virginia 23219
RE: Public Comment; opposition to adopting the Permanent Standard for Infectious
Disease Prevention: SARS-CoV-2 / 16VAC25-220
Dear Members of the Safety and Health Codes Board:
The Virginia Association of Surveyors (VAS) is a statewide professional association with membership of hundreds of licensed surveyors based in Virginia and others who do business in Virginia.
The Safety and Health Codes Board on July 15, 2020, adopted an “Emergency Temporary Standard for Infectious Disease Prevention” related to COVID-19. Now, the Board is considering adopting a Permanent Standard for Infectious Disease Prevention: SARS-CoV-2.
VAS strongly opposes the Board’s adoption of a Permanent Standard.
Surveying is a professional service and was deemed “essential” in the early weeks of the pandemic, by Governor Northam’s EO 53. Hundreds of Virginia surveyors have continued working in a safe manner. Our profession’s success during the pandemic has been due to quickly adapting to the Centers for Disease Controls (CDC) and Virginia Department of Health (VDH) recommendations to control or prevent infectious disease spread.
VAS opposes the Board’s adoption of a Permanent Standard for these reasons:
The surveying profession has risen to the occasion and effectively responded to the COVID public health crisis, as has many industries and professions. No matter the merit perceived by some for adopting an “emergency temporary standard,” there is considerably less merit for adopting a Permanent Standard for an evolving and hopefully resolvable public health circumstance.
VAS strongly opposes the proposed Permanent Standard and respectfully urges the Board to not adopt it.
Sincerely,
Kevin Wood, LS
President