Hello Members of the Safety and Health Codes Board,

I work for a large municipal organization, and have played a key role in developing, designing, and implementing our COVID response in compliance with the temporary standard, and then the Final permanent standard.  Trying to get 15,000 employees across 50+ agencies all into compliance with every aspect of the FPS has been a full time job, which was made more complicated by the conflicting information that was coming out from the various regulatory and health bodies.  Our Health Dept was following the science of the CDC, while we were responsible for informing and reminding that the final permanent standard was the law we must adhere to, or risk fines.  

The most difficult part of that was that the science changed much more often, the guidance from the CDC was updated often, whereas the FPS, as you know, must go through a much lengthier process to make changes and amendments.  It became harder and harder to tell employees they must comply with laws that did not match the science, but the law was the law.  In some instances  where employees would refuse to comply, it led to employees being terminated for non-compliance.  At a time when people needed jobs the most, ours were losing their jobs because the law did not match the science, and we were, and are, bound by the law. 

It is for these reasons, and the reality that the science changes much more rapidly than the law can keep up, that I urge the board to adopt new language that clearly mandates the FPS mirror the guidance of the CDC, or that the FPS be rescinded altogether.  This will give employers the agility they need to meet the demands of a rapidly changing situation.  

Thank you for your time and consideration.