Virginia Regulatory Town Hall
Agency
Department of Labor and Industry
 
Board
Safety and Health Codes Board
 
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8/23/21  11:32 am
Commenter: Anonymous

Edits and Updates Confusing: Please Scrap Original and Start from Scratch
 
Since July 2020, there have been many edits to this document. There have so many edits that there are parts of the standard that contradicts itself. This has made it nearly impossible to follow the intent of the standard. Instead of editing again and again, please start from scratch, just identifying that employers should follow CDC guidelines and include some guidance to go along with that. Other safety standards do not get into the "how" of implementing in the workplace, the updated standard is getting into this too much, which should be left up to employers and outlined in an employers IDRP. The vaccination "status"should not be included in the standard because this places an undue burden on workplace supervisors/managers to track and implement this sort of division among staff members/workforce. Instead, the protective measures should be all inclusive for both protection and implementation of the standard. The current standard is too convoluted and would be better for employers if it were more straightforward while also allowing employers to customize implementation of the standard in their own IDRP.
CommentID: 99860