Guidance on essential workers, businesses and critical infrastructure

NRCA provides the following guidance to members and affiliates to help address concerns regarding essential workers, businesses and critical infrastructure during the COVID-19 public health emergency. This guidance is intended to aid members as they deal with regulatory actions at the state and local government levels that may limit roofing industry activities.

On March 19, 2020, NRCA and roofing industry coalition partners sent a letter to President Trump and key federal departments requesting the administration provide guidance to state and local governments to address the importance of the roofing industry. See letter here. This letter can be used in any communications with state and local officials (agencies and legislatures) and other local officials who may be involved in decisions regarding essential workers, businesses and critical infrastructure.

On March 28, 2020, the Cybersecurity and Infrastructure Security Agency, located within the Department of Homeland Security, issued revised guidance for states and localities to use as they make decisions regarding business closures and restrictions. On April 17, CISA moved forward with an updated version 3.0 guidance document. This revised document, “Guidance on Essential Critical Infrastructure Workforce: Ensuring Community and National Resilience in COVID-19 Response,” can be found by clicking here. Please be aware this document is guidance and does not have the force of federal law or regulation.

In the document, we encourage you to reference the following sections in any efforts with state and local officials regarding these types of determinations with respect to roofing operations:

Public Works and Infrastructure Support Services

  • Workers who support the operation, inspection, and maintenance of essential public works facilities and operations, including bridges, water and sewer main breaks, fleet maintenance personnel, construction of critical or strategic infrastructure, traffic signal maintenance, emergency location services for buried utilities, maintenance of digital systems infrastructure supporting public works operations, and other emergent issues.

  • Workers such as plumbers, electricians, exterminators, builders (including building and insulation), contractors, HVAC Technicians, landscapers, and other service providers who provide services, including temporary construction, that are necessary to maintaining the safety, sanitation, and essential operation of residences, businesses and buildings, such as hospitals and senior living facilities.

Other Community- or Government-based Operations and Essential Functions

  • Workers to ensure continuity of building functions, including but not limited to security and environmental controls (e.g., HVAC), the manufacturing and distribution of the products required for these functions, and the permits and inspections for construction supporting essential infrastructure.

Critical Manufacturing

  • Workers necessary for the manufacturing of metals (including steel and aluminum), industrial minerals, semiconductors, materials and products needed for medical supply chains and for supply chains associated with transportation, aerospace, energy, communications, information technology, food and agriculture, chemical manufacturing, nuclear facilities, wood products, commodities used as fuel for power generation facilities, the operation of dams, water and wastewater treatment, processing and reprocessing of solid waste, emergency services, and the defense industrial base. Additionally, workers needed to maintain the continuity of these manufacturing functions and associated supply chains, and workers necessary to maintain a manufacturing operation in warm standby.

  • Workers who produce or manufacture parts or equipment that supports continued operations for any essential services and increase in remote workforce, including computing and communication devices, semiconductors, and equipment such as security tools for Security Operations Centers (SOCs) or data centers.

Commercial Facilities

  • Workers who support the supply chain of building materials from production through application and installation, including cabinetry, fixtures, doors, cement, hardware, plumbing (including parts and services), electrical, heating and cooling, refrigeration, appliances, paint and coatings, and workers who provide services that enable repair materials and equipment for essential functions.

  • Workers supporting ecommerce through distribution, warehouse, call center facilities, and other essential operational support functions, that accept, store, and process goods, and that facilitate their transportation and delivery.

  • Workers in hardware and building materials stores necessary to provide access to essential supplies, consumer electronics, technology and appliances retail, and related merchant wholesalers and distributors.

Residential/Shelter Facilities and Services

  • Workers performing housing and commercial construction related activities, including those supporting government functions related to the building and development process, such as inspections, permitting, and plan review services that can be modified to protect the public health, but fundamentally should continue and enable the continuity of the construction industry (e.g., allow qualified private third-party inspections in case of federal government shutdown).

Please use both the CISA guidance and the roofing industry coalition letter that NRCA and coalition partners sent to the National Governors Association March 24 to advocate with your state and local governments and state lawmakers as to the importance of roofing industry companies remaining operable. Governments and lawmakers need to understand roofing companies are available to service hospitals, government facilities, grocery stores, law enforcement, homes and other critical building functions during the COVID-19 crisis.

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