July 29, 2021
C. Ray Davenport
Virginia Department of Labor and Industry
600 East Main Street, Suite 207
Richmond, VA 23219
RE: Comments on Final Permanent Standard (FPS)
Dear Commissioner Davenport:
On behalf of the more than 13,000 members of the Virginia Society of CPAs (VSCPA), the VSCPA Executive Committee is writing to comment on the Final Permanent Standard (FPS) for Infectious Disease Prevention of the SARS-CoV-2 Virus. We request revocation.
The VSCPA appreciates the attention and careful consideration the Safety and Health Codes Board has devoted to this issue over the past year and a half. CPAs in public practice, as well as those in private industry and government roles, quickly pivoted and adapted their business practices to allow for remote work at the beginning of the pandemic in order to keep their staff, clients and other business associates safe. By the very nature of their work, CPAs are accustomed to following uniform guidelines and standards to ensure consistency. As the Centers for Disease Control (CDC), the Occupational Safety and Health Administration (OSHA), and others continue to update their guidance and recommendations based on the changing dynamic of the virus, it is critical for Virginia’s guidelines to have the flexibility to quickly evolve as well. Even with the proposed amendments, the FPS does not adequately account for the constantly evolving virus and ongoing revisions to federal guidance. It is our recommendation that Virginia rely solely on the federal guidance available as the standard for workplace safety measures. Adoption of separate standards makes compliance challenging for all businesses and institutions and may very well lead to failure to comply simply due to conflicting guidance.
The VSCPA is the leading professional association in the Commonwealth dedicated to empowering CPAs to thrive. Founded in 1909, the VSCPA has more than 13,000 members who work in public accounting, industry, government and education. Please feel free to contact me or VSCPA Vice President, Advocacy Emily Walker, CAE, at (804) 612-9428 or [email protected] if we can be of further assistance.
Stephanie Peters, CAE
President & CEO
Virginia Society of CPAs
CC: Patrick Cushing, Esq., VSCPA legislative counsel