Honorable Members of the Virginia Department of Labor and Industry Safety and Health Codes Board:

On behalf of Chesterfield County, Virginia we thank you for the opportunity to comment on the Department of Labor and Industry Safety and Health Codes Board's proposed revocation of the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220. Chesterfield County is one of the larger counties in the Commonwealth of Virginia encompassing over 460 square miles while providing critical infrastructure and essential services to over 365,000 citizens. The county government and public school district employs over 12,000 employees and we are committed to protecting the health and safety of our employees, students, citizens, contractors, and suppliers.

The COVID-19 pandemic has challenged us all in many ways over the past two years, both on a personal basis and as an employer. Chesterfield County has earnestly attempted to implement mitigation protocols within our workplaces that were risk-based, appropriate, effective, and protective of our employees and others who may utilize our services and facilities. At times we have found the guidance coming from the Virginia Department of Labor and Industry, the Virginia Department of Health, and the federal CDC to be confusing, not always grounded on a solid scientific basis, shrouded in uncertainty, everchanging, and onerous to implement.

It is now evident that the pandemic has taken a significant turn for the better across the Commonwealth and in Chesterfield County, as is evidenced by the rapidly declining number of new COVID-19 cases, significant reduction in case positivity rates, and decline in hospitalizations attributable to the predominant Omicron variant.

Chesterfield County agrees with and supports the DOLI Health and Safety Codes Board's acknowledgement that COVID-19 no longer presents a unique grave danger to employees in the workplace. Current thought is that the pandemic has entered an endemic phase and as such will become a ubiquitous community-based illness that has occasional flareups and hotspots. There is no longer a continued need for the existing workplace standard. We support and recommend that the Board vote to revoke the existing workplace standard at the end of the 30-day comment period.

Thank you for your effort to keep Virginia's workers safe and for your kind consideration.

Respectfully,

David B. Johnson, CSP

Director, Department of Risk Management and Chief Risk Officer

Chesterfield County, Virginia

cc. Hon Christopher Winslow, Esq. - Chairperson Chesterfield County Board of Supervisors, Hon. Leslie Haley, Esq. Vice Chairperson - Chesterfield County Board of Supervisors, Hon. Kevin Carroll - Member Chesterfield County Board of Supervisors, Hon. James Ingle - Member Chesterfield County Board of Supervisors, Hon. James Holland - Member Chesterfield County Board of Supervisors, Dr. Joseph Casey - County Administrator