Protect All Virginia Workers
I have 3 comments regarding this proposed standard:
Workers in high-risk categories need security that will not make the reopening a death sentence for them. There are 10 states that have already passed policies that allow workers who are immunocompromised, who live with someone who is immunocompromised; who don't have childcare; who are age 65 or older to not be disqualified from unemployment benefits if, for safety concerns, they do not accept an offer to return to work. This is an extremely important policy to protect Virginia's high-risk population and I encourage you to adopt it.
Second, I am concerned that some of the requirements around PPE ("Where the nature of an employee’s work or the work area does not allow them to observe physical distancing requirements, employers shall ensure compliance with respiratory protection and personal protective equipment standards applicable to its industry") are not specific enough. I am a union organizer who represents airport concessions workers. These workers experience long periods of exposure and are potentially in contact with many travelers, in addition to working in physically restricted spaces where physical distancing between coworkers is difficult. I do not believe there is an "industry standard" for their protection. I recommend more explicit requirements in your standard, for example for plastic face shields in addition to masks, and plexiglass shields between work stations.
Finally, I urge the board to adopt the proposed standard with teh above modifications, and also the elimination of Paragraph G on page 6, which allows employers to ignore this standard if they comply with CDC guidance. Because CDC publications are only suggestions, this could undermine the whole purpose of this emergency standard.