Members of the Safety and Health Code Board:

As an Executive in the Heavy Construction industry, I strongly oppose adopting a Permanent Standard for the Infectious Disease Prevention: SARS-COV-2 virus that causes COVID-19. The proposed standard has no specified edn date is based on a temporary standard for emergency health crisis for which there are two vacinnes now be distributed to Virginia with over 90% efficacy with several more candidates now in trials. 

The standard is burdensome, obsolete, difficult to enforce, costly in time and money, and lacks the flexibility to adapt to science and innovation. I am STRONGLY OPPOSED to the Adoption of a Permanent Standard., with no expiration date for what is a temporary health situation.

Construction is an essential business and our members have safely continued to provide essential infrastructure work during the pandemic. 

Construction is under CDC and OSHA guidelines,. Additional regulations are duplicative and costly. 

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

 I remain commited to the health and safery of all Virginians. 

Thank you for the opportunity to publicly comment. 

Ken Garrison 

Executive Director

Heavy Construction Contractors Association