Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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12/17/20  1:56 pm
Commenter: Stephen Craig, CHEMetrics

Incorporate OSHA text instead of reference by footnote
 

The newly added definition for "Minimal occupational contact" located in 16VAC25-220-30  includes a footnote reference to OSHA's Hazard Recognition web page.  The hyperlink referenced in the footnote on page 16 of the draft standard does not direct the user to the correct location.  I believe the correct reference is https://www.osha.gov/coronavirus/hazards#risk_classification

The OSHA web page includes a section with heading "Lower Exposure Risk" in which 5 examples of minimal occupational contact are provided.  These examples are more helpful in forming an understanding of the limits and extents of the definition than are the current words in the proposed standard.  

In the interests of consistency and best assisting the regulated community in proper risk classification, I suggest the five bullet point examples in the OSHA guidance be directly inserted into the definition in the proposed standard instead of simply being referenced by footnote.  

CommentID: 87848