Virginia Regulatory Town Hall
Department of Labor and Industry
Safety and Health Codes Board
Heat Illness Prevention Standard [16 VAC 25 ‑ 210]
Action NOIRA on Heat Illness Prevention
Comment Period Ended on 6/9/2021
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5/27/21  8:39 am
Commenter: Daniel Chahel

Unreasonable, unnecessary, and unfair

Many of the concerns that have been stated are already being addressed by businesses in this field. We have air conditioned areas (snackshops or showrooms) that employees can cool off if they feel they need to. Water is of course readily available. We have commercial fans in our service bays to aid in ventilation. 

This is not an industry where employees can realistically take 15 minute breaks every hour because often times they are working on complex repairs that require extended periods of concentration and focus to complete. You will directly be hurting the compensation of employees who have trained over years (sometimes decades) to be in a position to maximize their time and skillset. 

Some of the suggestions seem predicated on unfair assumptions about soda usage, alcohol, caffeine, and obesity. Those are private matters and it is unfair to shift the burden on the employer to address these aspects of an employees' lifestyle. 

Lastly, this past year has been one of the most challenging times for small businesses. For those of us that made it through this incredibly stressful time, we respectfully but firmly ask that you please do not make it even harder to survive going forward. More restrictions and regulations are not needed, especially right now. 

CommentID: 98873