On behalf of the King George County Service Authority Board of Directors, I am writing to express that we strongly oppose the proposed VOSH Permanent Standard for Infectious Disease Prevention of the SARS-Cov-2 Virus that causes COVID-19. VOSH should not move to adopt a permanent policy as it goes beyond the original temporary standard being that the current pandemic is a fluid situation that requires real time evaluation and adjustments. The permanent standard proposal being implemented by a regulatory agency would usurp the Commonwealth of Virginia's legislative process.

Furthermore, the VOSH standards being proposed, place both employers and employees at risk. First, it includes no prohibition on barring employees from coming to work after close contact with an individual who has tested positive for COVID-19; nor does it allow an employer to install testing based return-to-work polices. Second, several of its provisions relating to return-to-work and close contact do not allow employers to benefit from continually evolving CDC guidance. Third, it includes whistleblower protections for employees who report concerns to the news media or social media, which may invalidate some employers' media policies. Finally, the Proposed Permanent Standard lacks "safe harbor" protections for employers that protect employees by following CDC guidance. 

We strongly request  for you to reconsider this proposal and its implementation and allow agencies the ability to establish policy.

Respectfully,

Jonathon Weakley

General Manager, King George County Service Authority