Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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6/22/20  2:50 pm
Commenter: Mark Gero, AES LLC

Oppose based on a large one size fits all approach
 

To Whom It May Concern:

In  reviewing what I and many others deem A  "one size fits all" approach,  that fails to take into context the unique nature of different businesses sectors and workplace activities, I oppose.  Additionally, what has been proposed in regards to  Regulations are conflicting.  Such conflict inherently increases risk and safety for employers and employees. More open sessions should have taken place by the Commonwealth of Virginia to allow more public input.  

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,

Mark R. Gero

CommentID: 82902