Members of the Safety and Health Code Board,

As an employer in the heavy construction industry, I strongly oppose adopting a Permanent Standard for Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220. The proposed permanent standard has no specified end date and is based on a temporary standard for a temporary health crisis.

• Construction is an essential business that performs critical infrastructure work keeping society moving in the Commonwealth. The health and safety of our employees is the top priority of our company. A culture of safety is our primary operating principle. We implemented the CDC and OSHA COVID-19 guidelines for construction as soon as they were published and are in compliance.
• These guidelines were created to address a specific and temporary crisis, not to become a permanent standard for any and all unknown situations that may arise at some indeterminate time in the future.
• The standard would be unduly burdensome, costly, and have a deleterious effect on business if adopted on a permanent basis.
• The standard, if adopted, should expire concurrently with 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.

The standard is burdensome, obsolete, difficult to enforce, costly in time and money, and lacks flexibility to adapt to current 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 to the health and safety of my employees and thank you for the opportunity to publicly comment.