While we all can agree that the safety of all workers is our #1 priority but given the uncertainty and changing conditions of the situation it would be much more effective for the State to provide "guidance" over "regulations" based on the varying circumstances in the different businesses.  Having a regulation that fits all businesses is just not practical right now.  More guidance and training would be much more effective.  More time is needed to create a set of guidelines that better meets the needs of our construction industry.

Many businesses have already established a set of documents with best practices implemented to deal with COVID -19 and update accordingly as this fluid condition changes based on information from the CDC, VDOH and other federal government agencies as it specifically pertains to their business entity.  These set of regulations are very flawed in many ways and must have more time to create a set of regulations if that is what is desired from the State of Virginia that applies to the varying businesses.  Some of the items in these very vague regulations would be very difficult to implement in the construction industry as a whole with so many different conditions across the state. 

The vague definitions within these proposed regulations I feel only introduce more uncertainty than guidance.  A few points of note on what I mean:

While mandating that the appropriate PPE is required in certain scenarios, these regulations provide no guidance on what that appropriate PPE is.  Specifically, when and under what scenarios do they consider face coverings no long sufficient and respirators required?

Surveying and prescreening is referenced but it does not state what this should entail.

Contact within six feet is repeatedly sited without a reference on the exposure length of time.  What does this risk mean exactly?   How does this specifically impact the jobsite workforce?   The definition of "may be infected" could in theory represent a large portion of the workforce.  

It is mentioned that HVAC systems should be included in this regulations for maintenance and functionality.  Many employers that lease these spaces often do not have overall control of this lease space and for those that do the process of proving their systems comply with the regulations will be time consuming and costly. 

Contingency planning is something that is a good best practice it should not be in the regulations.

There needs to be more time and effort from VOSH into providing online consultation for employers to develop and update their COVID-19 plans and response and preparedness plans.  Many smaller companies are looking for help in providing a best practice plan to deal with this pandemic and do not need these regulations that are to say the least vague and confusing.  

While these current regulations in this unprecedented time may be of good intentions they must be further reviewed that work for the various businesses.