On behalf of the 13 national unions and environmental organizations that make up the BlueGreen Alliance, thank you for the hard work and dedication that has gone into the promulgation of the emergency temporary standard and the proposed revised permanent standard  to protect Virginia’s workers from COVID-19. 

The BlueGreen Alliance’s mission is to align the interests of labor unions and environmental organizations to provide common sense climate and environmental solutions that create family-sustaining jobs, build a fair and thriving economy and protect the health of workers and communities.  

We support the proposed standard because we believe that it is an important step towards ending this tragic pandemic and making Virginia’s workers, communities and economy healthier and stronger over time. 

The data show the extent of the COVID tragedy and the need for a permanent standard: 

• According to data from the Virginia Departments of Health, in the last nine months, more than nine times more Virginians have been diagnosed with COVID than the recent average year of Virginians diagnosed with all types of cancer.  
• If only 4 percent of the COVID deaths are workplace related in Virginia, the total is already greater than the number of job-related deaths of workers in the Commonwealth in any of the last five years. 
• The New York Times calculates that the number of cases in Virginia have gone up 21% in the last 14 days. And we haven’t yet witnessed the expected increase because of Christmas and New Years’ gatherings.

Virginia needs a permanent standard so these important state OSHA protections don’t expire before the COVID pandemic does.  The commenters who are questioning the need for a permanent standard may not understand that. Maybe they also don’t understand that once the pandemic is over, the permanent standard could be amended to become an infectious disease standard with appropriate changes or it could be repealed. And maybe they don’t understand that the issuance of a federal emergency temporary standard in the upcoming Biden Administration will still take some time before it can be enforced. Maybe they don’t understand that even if the initial transmission is at a private gathering, the workplace can be the way the virus dramatically  spreads.  Or that death is not the only long term impact of being infected by COVID. Or maybe they don’t understand that the absence of strong workplace COVID data is not the same as the absence of harm. None of these misunderstandings or the misinformation that these critiques are based on should prevent the promulgation of a permanent Virginia standard.

We second the concerns stated by our colleagues from ATU, VA AFL-CIO, UFCW and SEIU. In addition, there is one sentence in the proposed January 4 version of the proposed final standard that we suggest could be made more clear:

On page 22, number B2 under Mandatory requirements for all employers, it reads: 

Employers shall inform employees of the methods of and encourage employees to self- monitor for signs and symptoms of COVID-19 if employees suspect possible exposure

Is this sentence meant to require employers to inform employees of the methods of self monitoring?  Or is it meant to ensure that employees know the methods of reporting to their employers if they do have COVID signs or symptoms?  This is an important provision and we encourage the sentence to be rewritten to clarify its meaning. 

Again, thank you for all that you’re doing for the health and safety of Virginians inside and outside of the workplace.