Page 6, Item G - "To the extent that an employer complies with requirements contained in CDC publications to mitigate SARS-CoV-2 and COVID-19 related hazards or job tasks addressed by this standard/regulation, the employer’s actions shall be considered in compliance with this standard/regulation."

Comment - The CDC appears only to provide guidance and not requirements.  As written, this standard seems to make this guidance into requirements that is not attainable for employers to comply and could create substantial risk to employers when employees don’t follow all of the guidance based on their own free will. 

Page 6, Section 30 - Definitions

Comment - Please define what constitutes "contact" for the purposes of the document.

Page 12 - "Employee use of face coverings for close contact (inside six feet of) with coworkers, customers, or other persons is not an acceptable administrative or work practice control to achieve minimal occupational contact."

Comment - The CDC lists the use of cloth face coverings as an Administrative Control to prevent the spread of COVID-19 in work environments.

https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html#more-changes

Page 13, Item 4 - "Having traveled through a locality, city, town, or county, state, or country with moderate or substantial SARS-CoV-2 ongoing community transmission within the last 14 days and had contact with a person inside six feet while doing so."

Comment - Please explain how to determine moderate or substantial community transmission when traveling through localities.  Also, the standard seems to imply that simply walking past another person who is not known to have COVID-19 would be problematic. 

Page 17, Item 5 - "Employers shall not permit known COVID-19 or suspected COVID-19 employees or other persons to report to or be allowed to remain at work or on a job site until cleared for return to work or the job site (see §40.B)." 

Comment - It appears the words “who are symptomatic” may need to be added after “other persons” since this appears to contradict 3.c on the same page in the document.

Page 17/18, Item 6 - "Known COVID-19 and suspected COVID-19 subcontractor, contract, or temporary employees shall not report to or be allowed to remain at work or on a job site until cleared for return to work."  

Comment - It appears the words “who are symptomatic” may need to be added after “temporary employees” since this appears to contradict 3.c on page 17.

Page 20, Item C - "Unless otherwise provided in this standard/regulation, employers shall ensure that employees observe physical distancing while on the job and during paid breaks on the employer’s property. "

Comment - How does an employer ensure this?  The employer can’t be expected to follow around each employee to make sure or install cameras in every space.

Page 23, Item K - "… employers shall provide personal protective equipment to their employees and ensure its proper use in accordance with VOSH laws, standards, and regulations …"

Comment - Again, how does an employer ensure this?