September 25, 2020
C. Ray Davenport
Commissioner
Department of Labor and Industry
Richmond, VA
Re: 16VAC25-220, Proposed Permanent Standard, Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19
Commissioner Davenport,
Our organization places the wellbeing of our team members first and above all else, in all situations.
We have worked cooperatively with the Virginia Department of Health, as well as the Health Departments of several other states in which we are an essential manufacturer of food products. We also have established a cooperative relationship with Virginia DOLI/VOSH while managing this global pandemic.
We have found, in all cases, in the states where we work, the people in these government agencies have the same goal as we do – protecting people at home, in the community and in the workplace. We embrace the sharing of best practices to slow the spread of this pandemic, and without hesitation provide all of the protections we can in the workplace, complemented with a saturation of education to help our team members while at home and in the community.
Matters of public health are just that – matters of public health. Tuberculosis outbreaks, the common cold, the flu, and pandemics – are within the jurisdiction, including enforcement of the Virginia Dept. of Health, as well as local supporting health agencies.
The original, and sustained intent of the OSH Act is to require employers to evaluate and mitigate risks in the workplace, to provide protections to their employees of those risks that are a result of the hazards of the work in the workplace. The Act was not and is not intended for the employer to take a primary role in the accountability for spread of the common cold, the flu, or a global pandemic. These are social health issues and should not leak into the DOLI window of regulations and enforcement as it is outside of their scope.
DOLI / VOSH SHOULD HAVE NO STANDARD FOR COVID 19, EITHER TEMPORARY OR PERMANENT AFFECTING THE MANUFACTURING SEGMENT
DOLI / VOSH CAN PLAY AN IMPORTANT, VALUABLE ROLE IN SLOWING THE SPREAD AND CONTAINMENT OF THE PANDEMIC
IF THERE IS NO CHOICE BUT TO HAVE A TEMPORARY OR PERMANENT STANDARD
Sincerely,
Pat Strickland
Monogram Food Solutions
Vice President, Operations
Martinsville, VA