Working people are in desperate need for enforcable standards that require employers to plan for and protect them from COVID-19.

A more inforcable standard is needed to protect employees as voluntary guidance is a way to the needs of an industry over the health and safety of employees

Standard must clearly recognize 1) airborne transmission of the virus (which requires higher levels of adequate respirators and social distancing), and 2) asymptomatic transmission of the virus (which requires high levels of protection and quick removal from work with paid leave and employer reporting of cases to public health department and OSHA, etc.). The scientific evidence is clear.

We now know that all workplaces where workers are in close contact with the public or their coworkers are at high risk of exposure, such as meatpacking and corrections, not just in healthcare settings. The standard must ensure that all workers are protected equally from the virus through requiring an exposure assessment, infection plan, controls, reporting and training in ALL at-risk workplaces.

Leaving employers to determine risk. Employers must seek voices from employees, labor unions, etc to help determine risks within the work place

• The standard must include strong requirements for reporting and recordkeeping.

• This standard must also include provisions for workers who enter residences and other businesses where the employer does not control the environment.

• • Our Correctional/Detention Facilities have been hard hit with extremely high infection rates and outbreaks among both those incarcerated and officers and staff. As it has been unfortunately proven that the protections attempted by the Departments themselves have failed to stop the outbreaks and deaths from this deadly disease. The design of these facilities and interaction required does not allow social distancing or similar recommendations to limit the spread of the disease. This spread has happened even in cases where known Covid-19 cases were segregated in separate spaces. To categorize these facilities as “Medium” risk is a travesty given the rates of infection and deaths that we have seen, just in Virginia. These facilities must be categorized as “Very High” and appropriate steps mandated to protect everyone involved.