The VMA and the manufacturing sector are committed to protecting employees, contractors, suppliers and communities from COVID-19 infection.  We also have serious concerns about the regulations proposed and the process by which they are being promulgated.

It is unreasonable to apply "one size fits all" COVID-19 regulations to all employers and employees.  It is also profoundly inappropriate to bypass the formal regulation process altogether by attempting to codify guidance as a reasonable replacement.  Further, it is confusing why the regulations are being pursued through an emergency procedure now that the Commonwealth is poised to enter Phase 3 and the principal issues have been addressed at the Federal level.

Therefore, it is the VMA's recommendation that the Board reject the regulations.  For a detailed review of the rationale and reasons, go to https://files.constantcontact.com/d5b7f3a9001/2d0c9655-f66c-4d4d-9717-af2c7b537673.pdf