Dear Members of the Virginia Safety and Health Codes Board:
On behalf of the Precast Concrete Association of Virginia (PCAV), we are submitting the following comments related to your consideration of adopting an Emergency Temporary Standard/Emergency Regulation, Infectious Disease Prevention, SARS-CoV-2 Virus that causes COVID-19, §16 VAC 25-220, applicable to all employers and employees covered by Virginia Occupational Safety and Health (VOSH) program.
In totality, our organization of almost 40 member companies representing both precast concrete producers and associated industry partners, employs approximately 4500 Virginians in plants and offices throughout the Commonwealth.
As we enter the 15th week of Virginia’s State of Emergency related to containing the spread of COVID-19, the PCAV’s businesses are doing everything in their power to protect their employees and customers from exposure to the coronavirus by following the guidance issued by OSHA and the CDC. These existing safety standards already provide reasonable guidance and enforcement for businesses. The last thing business owners need during this critical time is additional one-size-fits-all, static government regulations and red tape.
The current approach is working—and no more standards are needed. To the contrary, mandatory one-size-fits-all standards such as the ones proposed to the Board could harm workers. It could quickly become outdated and constrain employers from pursuing the adaptable, innovative, data-driven, and effective approach to protecting worker health and safety that is proving crucial during this pandemic.
Therefore, we respectfully request you reject the proposed emergency regulations. Instead we encourage the Department of Labor and Industry to continue their current approach to investigate claims, notify businesses of complaints, work with businesses to ensure they are following proper procedures and issue fair fines when appropriate.
John C. Susong
Rinker Materials
Northeast Region Promotions Manager