Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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6/22/20  4:12 pm
Commenter: Deborah Blanchard

COMMENTS REGARDING EMERGENCY STANDARDS AND REGULATIONS COVID-19 REGULATIONS
 

I am a practicing dentist in Virginia Beach and I not only support the Virginia Dental Association request for an exemption for dentists from the proposed emergency regulations for the reasons stated in their letter dated 18 June 2010 but urge the board to reconsider the impact on these relatively long term emergency regulations on all businesses in the Commonwealth of Virginia.  The governors executive order forced economic instability upon businesses that were ordered closed.  Instead of protecting workers with these regulations, they have added additional burdens on businesses that will make their economic viability more unstable resulting in fewer jobs rebounding during this COVID-19 pandemic.   

Additionally, a worker with a "reasonable concern about infection control related to the SARS-CoV-2 virus and COVID-19 disease"  expressing this concern to his/her employer, the employer's agent, other employees or a government agency without fear of being fired or discriminated against seems consistent with past OSHA regulations; however, it is unreasonable to allow non-discrimination against such an employee who takes those concerns public through print, online, social, or any other media.  It removes the assumption of innocence on the employer's behalf as well as the government's requirement to inspect and investigate an unsafe practice to determine if it is actually an unsafe practice.  There is no need to encourage "mob rule" through social media intimidation.  

The length of this emergency regulation is limited to eighteen months which is far too long given the quickly evolving body of information about what are best practices as more is learned about COVID-19 and the SARS-CoV-2 virus.  One only has to review how much information and best practices have evolved in the last three months to appreciate that these regulations even with an expiration date of 18 months may well become outdated and burdensome in a short amount of time.  There is no incentive for businesses to open their doors and not institute safe practices; exposing employees and customers to SARS-CoV-2 virus and COVID-19 disease decreases a business' ability to provide goods and services and decreases customers desire for those goods and services.  Give businesses the ability to nimbly adapt to the evolving knowledge of how best to do business during this pandemic.

 

 

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