Regardless of how well meaning the proposed regulation being put forth, we must seriously object to the both the process and substance of the regulation.  The current pandemic is evolving and thus implementing a set of rules based on a point in time is not wise.  Our organization has been successful in implementing guidance from OSHA, VDH and the CDC because the guidance afforded flexibility.  OSHA regulations already provide for enforcement should these guidelines not prove effective.

We are also highly concerned the regulation making process is being circumvented with little comment period for regulation that is over 200 pages long and no public comments allowed during the meeting.  It is critical that extensive regulation such as this involve proper input from stakeholders.

VPGC began implementing procedures in February and 4 months into the pandemic our response is continually evolving.  We are a Virginia based company that ships product throughout the world and it is our employees that make this happen.  We do not need regulation to do what is right because we are concerned with our employee's welfare and safety everyday and have a track record that demonstrates this.  We have taken extensive measures such as employee education on best practices for mitigation.  We have implemented barriers throughout the facility despite very few of our areas requiring close employee contact.  We are providing PPE each day and implemented hazard compensation.  I could list nearly 100 additional steps we have taken to protect our employees and they have responded.

We urge you to avoid the news headlines and resist the practice of grouping Virginia meat facilities in with what has been publicized in other areas of the country.  VPGC has certainly not experienced this and it is wrong to subject our organization to unnecessary regulations given that our implemented program already surpasses many of the guidelines and does so in a more definitive manner.  The regulation as proposed offer more uncertainty and lack of consistency to respond to evolving federal and state government response.

Instead or requiring redundant and in some cases conflicting requirements, it would be much more productive to have VOSH to work alongside industry in a consultative role.  Together the two would provide greater value in developing infectious disease preparedness and response plans.

Thank you for the chance to comment on behalf our the 190 family farms we represent in our cooperative.  I appreciate the opportunity before us to improve our ability to grow Virginia agriculture instead of hampering with needless regulation.

John King, President