TO: Safety and Health Codes Board / c/o Jay Winthrow
FR: DuPont / Spruance / Richmond, Virginia / David Johnson, Plant Manager
Thank you for the opportunity to comment on the Virginia Department of Labor and Industry’s Safety and Health Codes Board Permanent Standard for Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19, 16 VAC24-220 (collectively, the “Regulations”). These comments are provided on behalf of DuPont.
DuPont has maintained a manufacturing presence in Virginia for over 90 years. Our three manufacturing locations in Virginia employ over 2000 employees and contractors. In addition, our Tyvek® protective apparel and our Dupont Teijin Films Melinex® film have played a critical role in protecting the front line essential workers in battling this pandemic.
Safety and Health is a core value at DuPont. Keeping the workplace safe, which has always been a cornerstone of our operation, has taken on new meaning during the past six months. The need to take extra precautions to protect the safety and health of our employees in the workplace as we continue to operate essential businesses is a value we share. While we appreciate and support critical measures which must be enacted to guard the health and safety of our employees, their families, co-workers and the communities in which they live, we believe the Regulations as drafted create concerns for many employers.
We respectfully submit the comments below addressing our specific concerns of the proposed Regulations:
Recommended changes: ASHRAE standards 62.1, 62.2 and 170 should be struck entirely and the Board adopt the CDC guidelines to adequately address the issue.
Keep systems funning longer hours, 24/7 if possible, to enhance air exchanges in the building space.
Suspected cases of COVID-19 – Symptoms
Section 30, “Symptomatic” definition – This definition includes a broad array of symptoms – “fever or chills, cough, shortness of breath or difficulty breathing, fatigue, muscle or body aches, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea or vomiting, or diarrhea.”
Recommended change: Narrow the symptoms that trigger a “Suspected case” to the CDC list to avoid abuse. Include a provision that would allow the employee to return to work upon if an initial COVID-19 test is negative.
PPE and no credit for the use of face coverings
Section 40.H – The draft states “. . . employers shall ensure compliance with respiratory protection and personal protective equipment standards applicable to its industry. “
Recommended Change: Allow the use of face coverings and surgical masks for work within six feet of others.
Recommended change: When multiple employees are occupying a vehicle for work purposes, the employer shall ensure all occupants wear a face covering, allow fresh air ventilation (i.e., open window) and limit occupancy to improve social distancing. If the employer cannot perform these tasks, the employer shall ensure compliance with respiratory protection and personal protective equipment standards applicable to the employer's industry.
Cleaning common spaces
Your time and consideration of the above stated proposals are appreciated.
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