June 22, 2020

Submitted Electronically

Jay Withrow, Director

Division of Legal Support, ORA, OPPPI, and OWP

Virginia Department of Labor and Industry

600 E. Main Street, Suite 207 Richmond, VA 23219 jay.withrow@doli.virginia.gov 

RE:       VA Department of Labor and Industry, Safety and Health Codes Board 

Emergency Temporary Standard/Emergency Regulation, Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19

To Whom It May Concern:

Thank you for the opportunity to comment on the Virginia Department of Labor and Industry’s recommended 16 VAC 25-220, Emergency Temporary Standard/Emergency Regulation, Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19 (collectively, the “Regulations”).  These comments are provided by the Virginia Manufactured and Modular Housing Association (VAMMHA). Originating in 1965, we represent the interests of the factory built housing industry including manufacturers, retailers, lenders, contractors, suppliers, communities, and support services.

Having reviewed the proposed regulations, it is our opinion that there is a better way forward. The inconsistencies, vagueness, impracticalities in the proposed regulations will create uncertainty in the business community and place an onerous burden on businesses trying to return to pre-COVID levels of operation. Our recommendation is to reject the proposed regulations.

Our sense from the field is that current guidance from the Department of Health and the Governor is working. My first hand inspection concludes that businesses in the factory built housing industry have taken steps as suggested by the Department of Health and the CDC to reduce the risk to employees and consumers. Systems are in place to prevent spread and to protect employees, consumers, and their families in the event COVID cases are found.

Respectfully submitted,

Randall Grumbine

Executive Director