January 8, 2021
Submitted Electronically
Jay Withrow, Director
Division of Legal Support, ORA, OPPPI, and OWP
Virginia Department of Labor and Industry
600 E. Main Street, Suite 207
Richmond, VA 23219
RE: Comments on behalf of the Richmond Area Municipal Contractors Association (RAMCA)
VA Department of Labor and Industry, Safety and Health Codes Board
Permanent Standard for Infectious Disease Prevention: SARS-CoV-2 Virus That Causes
COVID-19, 16VAC25-220
Members of the Safety and Health Code Board,
The Richmond Area Municipal Contractors Association (RAMCA) represents companies in heavy construction and their associate partners who provide products and services critical to the industry. For 56 years, RAMCA has worked cooperatively on a broad range of important issues relating to the infrastructure needs of the Commonwealth. RAMCA provides a forum designed to improve the business practices and the construction environment in which our employees work. The health and safety of our employees and the community at-large is our highest priority. Promoting a culture of safety is a primary operating principle of our employers. On behalf of RAMCA, I strongly oppose adopting a Permanent Standard for Infectious Disease Prevention: SARS-CoV-2 Virus that Causes COVID-19, 16VAC25-220.
Construction is an essential industry performing critical infrastructure work keeping society moving in the Commonwealth. The industry is heavily regulated under multiple federal and state occupational health and safety programs. RAMCA members immediately implemented and rigorously follow CDC and OSHA Guidelines for COVID-19 in the construction workplace.
The standard is burdensome, obsolete, difficult to enforce, costly in time and money, and lacks the flexibility to adapt to current science and innovation. On behalf of RAMCA, I am strongly opposed to the adoption of a Permanent Standard for what is a temporary health emergency.
The construction industry remains committed to the safety of our workers and the citizens of the Commonwealth. I welcome the opportunity to work with all stakeholders to develop any necessary policies regarding the health and safety of workers in the construction industry.
Thank you for the opportunity to publicly comment.
Best Regards,
Vanessa L Patterson
Vanessa L. Patterson
Executive Director
“Digging and Building in Central Virginia for 56 Years”