I want to take this opportunity to submit my comments on 16 VAC 25-220 Emergency Temporary Standard/Emergency Regulation Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19,

The provision allowing for employers to comply with CDC guidance as a replacement for following the Virginia standard must be removed. Voluntary guidance is never a substitute for an enforceable standard. Also, the CDC has watered down guidance during the pandemic due to industry desires instead of scientific reasoning and public safety.

The 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.).

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

Thank you for considering my comments,