I urge the board to adopt the proposed standard as a standard with the following very critical amendment. We urge the board to delete Paragraph G on page 6 (see below): If the board does not delete at least the paragraph below, then the standard will not protect VA workers from exposure to COVID 19 at work, and as the economy reopens in VA more workers will get sick and it will spread back into the community:

1. Delete the paragraph below, from page 6 , of the ETS document:
“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.”
The above paragraph would undermine all the protections required in the standard. It would allow employers to be in compliance with this proposed standard if they are following non mandatory CDC publications that are mere suggestions to employers. The CDC publications on COVID-19 are not requirements nor are they standards—they are written as suggestions. Thus the CDC publications to mitigate CARS-CoV-2 and COVID-19 related hazards state that employers should just consider these recommendations—the employer does not actually have to implement any of them. For example, the CDC publications are filled with non mandatory recommendations to employers in the meat and poultry industry include phrases such as “consider this” , or do this “if possible”. Thus employers say they are in compliance with these suggestions, if they have just considered something, and decided, it is just not possible. You must strike this paragraph –or workers will continue to be at risk at work in Virginia to COVID-19, and the disease will spread at work and back out into the community. All employers must comply with this standard and the requirements the standard—and not be allowed to use vague, recommendations and suggestions as cover to continue exposing workers to unsafe conditions in this Pandemic.