Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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8/20/21  12:55 pm
Commenter: Stephen Craig

No mechanism to notify regulated community of substantive changes through FAQ edits!
 

DOLI has adopted the use of FAQ's as their preferred method of adjusting the FPS to fit current CDC guidance.  I understand the need for flexibility in response to an ever changing situation, and although I believe it is of questionable legality, I am willing to accept this method of regulatory updates for lack of a better alternative.  What I find completely unacceptable though, is the lack of a mechanism by which the regulated community is informed of such changes.  I have become a nearly obsessive in checking the FAQs to look for new additions.  I thought I was really on top of the game.  And then I discovered that changes are being made by DOLI to the wording within their previous answers to FAQ's!!!  How in the world can we find time to figure out how to comply with the rules if we have to spend every waking minute performing comparative analysis of the entire content of the FAQ web page? PLEASE PLEASE PLEASE establish some obvious system of notification when there are changes being made to the standard by way of FAQ.  I'd love to be on an e-mail mailing list or get notifications through an app... something other than dumb luck of stumbling into new words.

CommentID: 99816