Members of the Safety and Health Code Board,

As an employee and executive officer of my organization, I strongly oppose adopting a Permanent Standard for Infectious Disease Prevention: SARs-CoV-2 that causes COVID-19, 12VAC25-220. The proposed permanent standard has no specified end date and is based on a temporary health crisis for which there are now 2 vaccines with over 90% efficacy. 

Construction is an essential business performing critical infrastructure work that keeps society moving in the Commonwealth. 

The health and safety of our employees is our company's top priority. We responded to the pandemic by implementing CDC and OSHA COVID-19 guidelines as soon as they were published and in compliance. 

The construction industry already operates under CDC and OSHA guidelines. Placing additional regulations are unnecessary and duplicative. 

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

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

The standard has been costly in time, money and resources and will become burdensome if it becomes permanent. The standard lacks flexibility to adapt to science and innovation. 

I AM STRONGLY OPPOSED to the adoption of a permanent standard with no expiration date that is geared towards a temporary health situation.

Our organization stands committed to the safety our employees and do not want to see this regulation continue to hurt businesses throughout the Commonwealth.

Thank you for the opportunity to provide public feedback.