The Virginia Association of Roofing Professionals (VARP) opposes the draft VDOLI COVID-19 regulations and has serious concerns about the process and lack of public participation in their development. In particular, we think that:

1. It is unreasonable to apply “one size fits all” COVID-19 regulations to all employers and employees.

2. Codifying guidance is not a reasonable replacement for regulation.

3. These regulations should not be promulgated through an emergency process and without public participation in the meeting of the Health & Safety Codes Board.

4. OSHA already 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.

5. VDOLI should focus on developing training curriculum for employers as well as assisting employers prepare COVID-19 infectious disease preparedness and response plans.

VARP takes its responsibility to the public seriously. The VDOLI COVID-19 draft regulations will only make a difficult situation worse for employers, employees, and their customers - the public. We encourage you to focus your time and attention on bad actors that knowingly violate COVID-19 guidance.

Thank you,
Heather Greenwell, CAE
VARP Executive Director