I have reviewed the document and believe it is best to establish a Temporary Emergency Regulation utilizing VA Code 2.2-4011 rather than VA Code 40.1-22(6)a.  I reviewed the Summary Chart on p.165 of the agenda documents and VA Code 2.2-4011 allows the regulation to receive review from multiple parties and it can be appealed in Courts Statewide.  A Temporary Emergency Standard utilizing VA Code 40.1-22(6)a can only be appealed in Richmond, VA.  There is a need for this regulation to protect workers health and the current VOSH regulations do not address COVID-19.  Once a vaccine is available this temporary regulation can be eliminated.