Members of the Safety and Health Code Board,

As an employer in the heavy construction industry, I oppose adopting a Permanent Standard for Infections 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 96% efficacy and several more candidates are nearing the end of their trials. 

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 exception, for what is a temporary health situation.

I remain committed to the health and safety of my employees and thank you for the opportunity to publicly comment.

Susan Arnold | Principal, Insight, LLC