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Sample Messaging Points on the Proposed Permanent MIOSHA COVID-19 Workplace Safety Rules

The Michigan Occupational Safety and Health Administration (MIOSHA) is looking to move forward with permanent COVID-19 Workplace Safety rules on employers of all sizes and types and across all industries.  We are opposed to the proposed permanent rules, because they fail to address commonsense concerns, do not reflect the rapidly changing environment related to the pandemic and directly contradict the Governor’s “Vacc to Normal” plan announced on April 29.

To successfully fight back on these rules, we need your help!  Share your story with MIOSHA at the upcoming public hearing on the ruleset.  There are two key ways to get involved:

  • Share your story and voice concerns about these unhelpful rules in advance of MIOSHA’s public hearing on May 26. 
    • Comments on the proposed rules may be made by email or postal mail until 5 p.m. on May 26 to MIOSHA, attention Toscha Klopp.  Email: kloppt@michigan.gov or mail:  Department of Labor and Economic Opportunity – MIOSHA, Technical Services Division, Standards and FOIA Section – 530 West Allegan Street – P.O. Box 30643 – Lansing MI 48909-8143.

 

  • Participate in MIOSHA’s virtual public hearing on May 26 at 9 a.m. via phone, web or Microsoft Teams and speak out in opposition to these rules.

 

Here’s a sample of what you might say or write:

  • Introduce yourself and/or your business (e.g., industry, location, number of employees, etc.).
  • Voice your opposition to the proposed permanent MIOSHA COVID-19 Workplace Safety Rules (Part 505, Coronavirus-19 (COVID-19), Rule Set 2021-27 LE).
  • Share your story.  Examples:
    • Share the impact the pandemic and current restrictions have had on your business/operations, employees, city/region.
  • Explain why you are opposed to the permanent MIOSHA COVID-19 Workplace Safety Rules.  Examples: 
    • Business owners across the state have borne the economic brunt of the state’s response to the COVID-19 pandemic.   Since March of 2020, employers have been told they must keep employees working from home versus the office, tasked with enforcing the Governor’s mask mandate, enforcing the six-foot social distancing requirements and countless other mandates.
    • The rules lack a clear sunset date for when the rules would end.  Given the widespread availability of vaccines, job providers deserve to understand when these regulations will come to an end.  As written, the proposed rules wouldn’t even be guaranteed to expire after the Michigan Department of Health and Human Services declaration has ended!
    • The rules need to provide more flexibility for Michigan’s workplace safety rules to be updated and changed as the CDC guidelines and science changes. 
      • We are over 14 months into the pandemic.  The science and the Center for Disease Control (CDC) guidance has evolved since the first workplace restrictions were put in place in March of 2020.  The rules and restrictions should continue to evolve too.
      • The MIOSHA rules need to provide greater flexibility for Michigan to adapt as updated guidance is released from the CDC as it relates to proper PPE standards, workplace protections, quarantine guidance, physical distancing, how to handle vaccinated versus non-vaccinated employees and other, current information to combat COVID-19.
        • For example, the updated CDC guidance suggests individuals who are fully vaccinated can gather indoors with other fully vaccinated people without wearing a mask or social distancing.  However, the proposed permanent MIOSHA rules (Rule 7) do not address this issue and, instead, require everyone on the worksite to social distance and to wear face coverings.
    • The remote work requirements are unnecessary and overreaching.  The proposed rules micromanage employers by requiring them to “create a policy promoting remote work for employees to the extent that their work activities can feasibly be completed remotely.”   Government should not be inserting itself into these types of decisions.  These decisions are best made in the workplace between employers and employees.
    • The rules provide a top-down, one-size-fits-all approach.  Businesses need the flexibility to adopt, adapt and implement safety measures that match their operations and specific situations.
    • The rules contradict and conflict with Governor Whitmer’s “Vacc to Normal” plan, released on April 29.  The “Vacc to Normal” outlines a plan for rewarding workers and businesses for their efforts to vaccinate and stay safe.  However, MIOSHA’s indefinite and permanent rules don’t mention the word “vaccine” even once.  This sends a different and contradicting message to employers and employees alike.  If the MIOSHA rules go into effect as written, employers would still have to require their employees to wear masks, “promote” remote work and socially distance indefinitely—and even if the entire workplace is fully vaccinated.
    • MIOSHA should follow the lead of the Governor and, like other states, move to start easing its COVID-19 restrictions and regulations.  Now is not the time to be adding new layers of regulations.
  • Urge MIOSHA to rethink its approach.
    • We urge MIOSHA to reconsider its proposed permanent COVID-19 workplace safety rules.  Employers and employees alike should not be further penalized by this type of permanent government overreach.

Please send a copy of your remarks to your State Representative and Senator.