To Whom It May Concern:

It is my desire as an employer to provide as safe as reasonably possible working environment for myself and my employees.  In reviewing the proposed Regulations, it is my opinion that these proposed regulations are a "one size fits all" approach that fails to take into context the unique nature of different businesses sectors and workplace activities.  Additionally, what has been proposed Regulations are conflicting.  Such conflict inherently increases risk and safety for employers and employees.

I would also like to reiterate the concerns and opposition expressed by the Virginia Business Coalition to the proposed regulations.  

"It is unreasonable to apply 'one size fits all' COVID-19 Regulations to all employers and employees.  Codyfiying guidance is not a reasonable replacement for regulation.  It is confusing why after three (3) months, the Regulations are being pushed through an emergency procedure, especially after OSHA rejected the AFL-CIO's petition for an emergency temporary standard for COVID-19 and the US Court of Appeals for the District of Columbia Circuit denied their petition for a writ of mandamus to compel OSHA to issue an Emergency Temporary Standard for Infectious Diseases."

I urge you to reject the proposed Regulations and thoughtfully consider regulations that will be much more clear, concise and address the uniqueness of each business sector, business size and workplace activities.

Sincerely,

Scott Shufflebarger

President

HERTLESS BROTHERS ROOFING, INC.