VOSH should consider making recommendations, but not requirements.  Every employer has responded to this pandemic as reasonably as possible.  Employers have evaluated their level of risk, made significant adjustments to minimize exposure, and are continuing to monitor their workforce and workspaces accordingly. 

Many of the proposed regulations are either not specific (how will you determine if an organization acted "where feasible" or not?) or are too restrictive.  For example, requiring a Firefighter who is responding to a call to stop and put on surgical gown, gloves, eye protection, etc. is ridiculous, considering they are already wearing turnout gear, which is just as, or more, protective.  These requirements give the impression that all organizations are the same.  We are not.  This pandemic and how we react is not a "one size fits all."  Even within local government, in the same region, we have seen significant differences.  To hold us all to the same standards is not right, nor is it productive. 

In addition, the threat of fines is too harsh.  From the beginning of the pandemic, there has been more emphasis on punishment than trying to support best practices and supporting each other. 

We fully support sound recommendations, but feel these proposed requirements go too far.