Members of the Safety and Health Code Board,

As an employer in the construction industry, I strongly oppose adopting a Permanent Standard for Infectious Disease Prevention: SARS-COVID-19, 16VAC25-220. The proposed permanent standard has no end date and is based on a temporary health crisis for which there are now 2 vaccines being distributed in Virginia with over 90% efficacy and more candidates nearing the end of their trials.

1. Construction is an essential business performing critical infrastructure work that keeps things moving in the Commonwealth. The health and safety of all employees is the top priority of our company and safety is our primary operating principle. We implemented the CDC and OSHA COVID-19 guidelines for construction as soon as they were published and are in compliance.
2. Construction works under the CDC and OSHA guidelines; additional regulations are unnecessary.
3. The proposed permanent standard is burdensome, quickly obsolete, difficult to enforce, costly in time and money and does not adapt to current science and innovation.
4. If anything is adopted, it should have a sunset provision that ends with the Governor's state of emergency. There is not a logical or scientific reason to continue a standard that was specifically written in response to a state of emergency 
5.  The data has not shown direct of immediate danger for workers in the "low" and "medium" categories as defined in 16VAC25-220-30. These categories should be removed from the permanent standard, since those industries are regulated by OSHA.

The standard is burdensome, obsolete, difficult to enforce, costly in time and money and does not allow flexibility to adapt to current science and innovation. I am STRONGLY OPPOSED to the adoption of a permanent standard with no expiration.

Sincerely,

Dennis Showalter

President / Owner

Insight, LLC