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Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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9/24/20  11:36 am
Commenter: Jeff Stapel

Strongly Oppose Permanent Standard

The ETS once published is flawed because it is trying to deal with regulating a medical condition that is not well understood, studied or static.  With a virus that the CDC is constantly changing it's protocols on, responding to new research and findings, new testing means and processes, and reinterpreting the means and methods of data collection which the very definition of a pandemic are based on, how can a regulation not be obsolete as soon as it is published.  There is a need for flexibility and adaptability for businesses to be able to deal with this changing landscape which ETS does not provide currently.  If it is not able to adjust not to the changing information and needs, how will it if it is made permanent. The reliance on sanitizing surfaces when there is not reliable science to show the transmission from surfaces exists.  The reliance on masks where there is not reliable science to show that it is effective.  The reliance on social distancing and the definition of close contact which there is not sufficient research to support the effectiveness of these strategies in the current time and for all future situations.  The presumptions which this standard is built on have not been substantiated by sufficient science tested over time to make it reliable to base a regulatory standard upon. Let the ETS end then allow sufficient review and research to be done to determine what really was the best response to COVID-19.  Then consider if a regulatory response is ever going to be able to predict the best future response to a viral pandemic that will have numerous unknown variables. That is not what regulations do best, ever!

CommentID: 85745