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Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
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9/25/20  11:38 am
Commenter: Betty Groth, Pinnacle Construction and Development Corp

Strongly Oppose the Standard

Strongly Oppose the Standard

Dear Safety and Health Codes Board Members,

On behalf of Pinnacle Construction and Development Corporation, I urge you to oppose the adoption of a Permanent Standard for SARS-CoV-2, which will make permanent the current temporary standards.

A brief summary of concerns:

  1. It’s confusing: the standard conflicts with federal and state regulations and ever-changing guidance and recommendations. Language is vague.
  2. It’s burdensome: review, response, training and implementation of the standard imposes a substantial cost in time and money for the Virginia companies who have been able to remain in business.
  3. It’s unnecessary: a permanent standard for a temporary health situation simply doesn’t make sense.
  4. It’s obsolete and inflexible: the temporary standard was obsolete upon issuance. The permanent standard is similarly inflexible and doesn’t take in to account the updated scientific findings and recommendations.

As an essential business with ongoing construction projects including affordable housing and assisted living facilities, we implemented our initial action and response plan in early April. This plan, and related safety protocols based on current state and federal requirements has helped protect our team members and our workplace.

We do not believe in permanently imposing constrictive emergency standards.  We have and will continue to adapt to workplace safety protocols including masks, social distancing and specific sanitization and disinfecting practices to keep our teams safe and working.

CommentID: 86181