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9/25/20  3:30 pm
Commenter: Scott Tilley, General Counsel, STIHL Incorporated

Significant concerns with proposed permanent standard

STIHL Incorporated is the largest manufacturer and one of the largest private employers in Virginia Beach.  As a manufacturer of essential equipment under the CISA definition, STIHL has been following CDC guidance for critical infrastructure workers since the beginning of the pandemic.  The lack of clarity in the Emergency Temporary Standard, as well as inconsistencies with the CDC and other agencies/guidance (and even within itself) have been of significant concern to manufacturers and essential employers like STIHL.  The "one size fits all" approach of this standard cannot work for the diversity of businesses, and even manufacturers, in the Commonwealth.  It is even more concerning that such inconsistencies and lack of clarity are making their way into the Proposed Permanent Standard.  STIHL remains committed to protecting the safety of its employees while fulfilling its critical role as an essential manufacturer.  Thus, for the reasons stated above, STIHL joins in the detailed comments submitted by the Virginia Manufacturers Association and the Virginia Chamber of Commerce in opposing the adoption of the Proposed Permanent Standard or at least delaying it until the detailed comments and concerns can be sufficiently addressed.  

CommentID: 86330