Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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6/22/20  10:31 am
Commenter: Sookyung Oh, NAKASEC Virginia

Protect all Virginia workers
 

To Whom It May Concern:

As an organization that works with Asian American communities in Northern Virginia, primarily those who are undocumented or lower-income or limited English proficient, a priority for them is safety - their safety and that of the public. With that perspective, we offer the following recommendations:

1) eliminate Paragraph G on page 6, which allows employers to ignore this standard if they comply with CDC guidance. CDC publications are only suggestions and this could undermine the whole purpose of this emergency standard.

2) Classify meatpacking as a "high" exposure risk or job task. It has been widely reported that areas in Virginia with meatpacking facilities have been hot spots in part because workers operate in proximity to one another in enclosed spaces.

3) Mandate the use of masks or face coverings when engaged in work, whether at the workplace or performing work off-site. There could be some exemptions like persons with a medical or mental condition where a face covering could obstruct breathing or persons who are hearing impaired or communicating with a person who is hearing impaired, where the ability to see the mouth is essential for communication. Otherwise, there is much evidence to suggest that the use of face masks helps reduce the spread of COVID-19. Face masks are not a substitute for physical distancing. Both should be used.

Sincerely,

Sookyung Oh

CommentID: 82360