The Virginia Bankers Association represents banks of all sizes and charters and has served as the organized voice for Virginia’s $615 billion banking industry and its 42 thousand employees since 1893.  We appreciate the opportunity to comment on the proposed regulation. 

Clarification is needed in Section 80 of the proposal that training is only required for employers with hazards or job tasks classified at “very high” or “high” exposure risk.  The requirement in Section 40 A 3 that all employers develop and implement policies and procedures regarding antibody testing conflicts with guidance issued by the Center for Disease Control and Equal Employment Opportunity Commission.  Finally, the proposed regulation lacks a clear timeline for when employers are required to be in compliance, particularly in regard to response plans and required training where the Department has not provided any details or templates.

Thank you. If you have any questions, please feel free to contact me.