Members of the Safety and Health Code Board,

As an employee 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 for which there are now 2 vaccines distributed to Virginia with over 90% efficacy with several more candidates nearing the end of their trials.

The standard, if adopted, should sunset upon 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.

What metrics, scientific data, or criteria would the Safety and Health Codes Board use to continue a standard for COVID-19 after the Governor, a physician, has allowed the State of Emergency to expire and the Commissioner of Health has determined COVID-19 no longer presents a public health emergency for Virginians?

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 coworkers and thank you for the opportunity to publicly comment.