On behalf of our hard-working members, we are in strong support of the Proposed Permanent Standard for Infectious Disease Prevention for COVID-19, which would make these essential standards a permanent protection for workers in Virginia. 

There is no way out of this pandemic without a permanet standard to protect workers, our families, and our communities across the commonwealth. Without a permanent standard, we will not be able to protect those on the job, or get those who are without work back on the job.

We have the following recommendation to strengthen the standards:

1. The state is proposing delayed effective dates for some elements, such as training. This would (wrongfully) cause a lapse in coverage for workers since these protections are already required under the emergency standard. The rule must go into effect immediately.
2. The Virginia Department of Health has proposed changes to the rule to allow face coverings when respirators are actually needed to address the airborne nature of this highly contagious virus. Reducing needed protections because of any shortages in supplies must not be in the rule itself and should be handled through enforcement discretion, as the agency always has. Face coverings must be allowed only for protecting others from the person wearing them, and not in place of adequate respiratory protection that many workers need when working close to other people for long periods of time.
3. There is a new requirement to train workers on how to extend the use of PPE. Reusing single use PPE in the workplace is dangerous and places everyone at risk. This provision must be removed. Instead, workers must be trained on how to properly use PPE and on what makes them effective. Any extended use during critical, actual shortages should be done in limited and extreme circumstances and handled through enforcement discretion and not the final rule. This proposed provision lowers the bar or everyone and is harmful.
4. The return-to-work provisions have been updated to be consistent with current CDC guidance. However, guidance for how to return workers with asymptomatic COVID-19 is uncleare and must be addressed.

The ETS is a strong, comprehensive standard that sets clear requirements based on longstanding practices and current science, and should be made permanent while implementing the changes we outlined above.

We urge you to do what is right to protect Virginia's workers and adopt the proposed January 4, 2021 Permanent Standard with our recommended changes. 

In Solidarity,

David Broder, President

SEIU Virginia 512