Members of the Safety and Health Code Board, 

As an employee in the heavy construction industry, I strongly oppose adopting a Permanent Standard for Infectious Disease Prevention: SARs-CoV-2 that causes COVID-19, 16VAC25-220. You are risking my job by putting more regulations in place. 

The proposed permanent standard has no specified end date and is based on a temporary health crisis for which there are now 2 vaccines (and more forthcoming) to Virginia with over 90% efficacy. 

Construction is an essential business performing critical infrastructure work keeping society moving in the Commonwealth of Virginia. The health and safety of all employees is a top priority of our company. A culture of safety is a primary operating principle. We quickly implemented the CDC and OSHA COVID-19 guidelines as soon as they were published and are in compliance. 

The proposed permanent standard is burdensome at a minimum, quickly obsolete, difficult to enforce, costly in time and money and lacks flexibility to adapt to current science and innovation. 

Construction already works under CDC and OSHA guidelines. Placing additional regulations are duplicative and unnecessary. 

The permanent standard, if adopted, should sunset on the expiration of the Governor's COVID-19 State of Emergency. There is no logical or scientific justification for the continuance of a standard specifically crafted in response to an Executive Order during the COVID-19 State of Emergency. 

It is unclear to us, what metrics, scientific data, or criteria the Safety and Health Codes Board would use to continue a standard for COVID-19 after the Governor, a physician, has allowed the State of Emergency to expire and the Commissioner of Health has determined COVID-19 no longer presents a public health emergency for Virginias. 

The data has not shown a direct or immediate danger for those workers whose tasks fall into the "Low" or "Medium" categories as defined in 16VAC25-220-30. These categories should be removed from the Permanent Standard for those industries regulated by OSHA. 

The standard has been and is currently costly in time and money and if it becomes permanent will be burdensome, obsolete, difficult to enforce and continue to be costly in terms of time and money. It also lacks flexibility to adapt to science and innovation. I am STRONGLY OPPOSED to the adoption of a Permanent Standard, with no expiration, for what is a temporary health situation. 

I remain committed, as always, to the health and safety of my employees and thank you for the opportunity to provide public feedback. Please do not continue to hurt our business and other businesses with these regulations. I need my job and these regulations will cause more layoffs by businesses.