March 17, 2022
Commissioner Gary G. Pan
Department of Labor and Industry
600 E. Main Street, Suite 207
Richmond, Virginia 23219
Re: Proposed Revocation of the Virginia Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220
Dear Commissioner Pan:
The Virginia Bankers Association (“VBA”) represents banks of all sizes and charters and has served as the organized voice for Virginia’s $615 billion banking industry and its 42 thousand employees since 1893. We appreciate the opportunity to comment on the Department of Labor and Industry’s Proposed Revocation of the Standard for Infectious Disease Prevention of the SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220 (“DOLI Standard”).
The VBA strongly supports revocation of the DOLI Standard. Virginia banks unwaveringly provided banking and financial services to their customers throughout the pandemic. They have invested substantial time and resources protecting the health and safety of their employees related to COVID-19, and will continue to do so in alignment with the most current guidance from the Centers for Disease Control (“ CDC”) and Virginia Department of Health. The DOLI Standard is not needed and should be revoked because of the existing Virginia General Duty Clause, the increased vaccination rate, downward infection trend, and employer familiarity with infectious disease safety protocols. The VBA requests that any guidance document adopted by the DOLI Board for employers to mitigate the risk of COVID-19 to their workers be comprised of essential uncomplicated recommendations that are aligned with CDC guidelines.
Thank you for the opportunity to provide comments. If you have any questions, please feel free to contact me at 804-819-4701 or firstname.lastname@example.org.
Bruce T. Whitehurst
President & CEO