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The COVID Project

How a Typical Employer in Trucking, Logistics, Warehousing, Wholesale and Distribution Operates

A typical employer in this industry sells the movement and storage of other people's goods; its revenue is a derivative of its customers' commerce, its labor is credentialed by the State, its routes cross every jurisdiction's line, and its inputs come from the plants, ports and borders the orders reached. Every function described below has an order that reached it in every one of the six quarters, and the sections that follow identify those orders by exhibit.

Scale and structure

The industry is large and its firms are small. Truck transportation employs about 1.47 million people in about 171,000 establishments, among them about 900,000 heavy and tractor-trailer drivers and about 57,000 bus and truck mechanics; warehousing and storage employs about 1.84 million in about 23,800 establishments, among them about 458,000 stock clerks and order fillers, 433,000 laborers and freight movers and 287,000 industrial truck operators; wholesale trade employs about 6.07 million in about 628,000 establishments; and support activities for transportation, including freight arrangement, employs about 830,000 in about 59,000 establishments with about 62,000 cargo and freight agents.1 Nearly 580,000 motor carriers are active, and 91.5 percent of them operate ten or fewer trucks.2 The Census Bureau's Monthly Wholesale Trade Survey groups merchant wholesalers by kind of business (motor vehicles and parts, furniture, lumber, professional equipment, metals, electrical, hardware, machinery and miscellaneous durables; paper, drugs, apparel, groceries, farm products, chemicals, petroleum, alcoholic beverages and miscellaneous nondurables), the same kinds of business Pennsylvania's list divided into "Yes" and "No" on March 19, 2020.3 The Cybersecurity and Infrastructure Security Agency's guidance, which nearly every State's closure order incorporated, names under "Transportation and Logistics" the "truck drivers, ... dispatchers, maintenance and repair technicians, warehouse workers, truck stop and rest area workers, ... Department of Motor Vehicle (DMV) workers" on whom the industry runs; the designation meant permission to operate under conditions, and the conditions are the orders set out in the layers below.4

DS, dispatch and brokerage

Load tendering, carrier procurement, spot and contract pricing, tracking and exception management run from a dispatch office. Brokerage revenue is the spread between the shipper's rate and the carrier's pay; an asset carrier's dispatch office is the "office" the telework mandates reached. New York ordered every business to "utilize, to the maximum extent possible, any telecommuting or work from home procedures" and to cut its in-person workforce outside the essential list to zero; New Jersey's Executive Order 107 directed every business to "accommodate their workforce, wherever practicable, for telework or work-from-home arrangements"; Pennsylvania's Secretary of Health ordered on November 23, 2020 that "[u]nless impossible, all businesses must conduct their operations remotely"; Michigan's occupational-safety rules of October 14, 2020 required a policy "prohibiting in-person work for employees to the extent that their work activities can feasibly be completed remotely."5 Dispatch also runs on its customers' shipping offices and receiving desks, which the same orders closed or sent home.

DR, drivers and routes

Truckload, less-than-truckload, dedicated, drayage, intermodal and final-mile operations earn revenue per mile or per load. A driver's rest, food, fuel and lodging depend on truck stops, rest areas, service plazas and hotels; Vermont's Addendum 7 and Maine's Executive Order 34 closed lodging except for enumerated purposes, Pennsylvania closed every Turnpike service plaza on March 17, 2020 and reopened them March 20 with restrooms and limited take-out only, and every State's dine-in closure closed the truck-stop restaurant.6 Routes cross State quarantine lines and checkpoints (Texas GA-12 with Department of Public Safety enforcement on the Louisiana border; Florida's Interstate 10 and 95 checkpoints; New York's Executive Order 205; Connecticut's 7III; Massachusetts Order 45; Pennsylvania's test-or-quarantine order; Alaska's Health Mandate 010; the quarantine orders of Maine, Vermont, New Mexico, Hawaii and others) and two international borders where travel was limited to "essential travel" for twenty months.7 From February 1, 2021 the conveyance order's airborne-transmission control, a mask on every person, was federal law in every cab with more than one occupant and at every port and port of entry the driver entered.8

WH, warehouse and dock

Receiving, put-away, storage (billed per pallet per month), picking, packing, value-added services, cross-docking and fulfillment run on a floor whose density, flow, shift pattern and staffing the workplace orders governed: New Jersey's eleven rules for "warehousing businesses"; New York's fifty percent occupancy, six-foot and face-covering requirements for wholesale trade; Ohio's mandatory "Manufacturing, Distribution & Construction" sheet ("Ensure minimum 6 ft between people, if not possible, install barriers"; "Face coverings must be worn at all times"; "Establish maximum capacity (e.g. 50% of fire code)"; "Change shift patterns (e.g. fewer shifts)"); Minnesota's mandatory COVID-19 Preparedness Plans; Pennsylvania's Worker Safety Order; the Cal/OSHA, Virginia, Michigan, Oregon and Washington standards; and, from July 2021, the indoor face-covering orders of the freight metros, workplace exposure-control requirements on every floor, and OSHA's programmed inspections of NAICS 493110.9

MT, maintenance

Shops, parts rooms, tire service and inspections keep the fleet on the road. Parts came from plants that Michigan, Ohio and Indiana closed in the spring of 2020 and from Mexico and Asia under foreign closure decrees; State inspection stations closed (New Jersey's Motor Vehicle Commission closed its inspection facilities from March 16 to July 7, 2020); and the shop floor was a workplace under the same conditions as the dock.10

CS, customer facilities

Every pickup and every delivery occurs at a shipper's or receiver's dock under that facility's orders. A closed store, restaurant, office, construction site or plant has no dock to deliver to; an open hospital, nursing home or grocery received under visitor bans, screening, driver-stays-in-cab rules, appointment windows and paper-free documentation that the receiving facility imposed under its own State's order.11 The customer-side orders of every other industry analysis on this site are, for this industry, the orders on CS.

PT, ports, rail and air cargo

Port gates, chassis pools, rail ramps and air-cargo terminals operated under the regime the Coast Guard's Marine Safety Information Bulletins implemented and recorded (the Captains of the Port's orders and the vessel-reporting and facility-security regulations as applied to essential maritime workers, vessel reporting, crew changes, credentials and TWIC enforcement, and, from February 1, 2021, the CDC conveyance order's airborne-transmission control, its mask requirement, on every commercial vessel and at every sea port; the bulletins are cited as evidence of that regime and not as orders), the Federal Railroad Administration's Emergency Order No. 32 on "all freight rail operations," the conveyance order at every hub, the Federal Maritime Commission's Fact Finding 29 on supply-chain congestion, the Federal Aviation Administration's exemptions permitting cargo in passenger cabins, and the port authorities' own access orders.12

HR, hiring and licensing

Driver hiring depends on commercial driver license skills testing, medical certification, drug and alcohol testing and the motor-vehicle office. Motor-vehicle agencies closed their offices in nearly every State between March 16 and March 27, 2020 under the States' emergency orders and reopened them by appointment months later, as their closure notices record; skills tests were suspended; the Department of Transportation's Office of Drug and Alcohol Policy and Compliance recorded in its enforcement statements of April 4, 2020 and May 27, 2021 (the latter effective through December 31, 2021) that collection sites and service agents were closed or limited; and FMCSA's own notice records that COVID-19 "impacted SDLAs and their operating statuses."13 Warehouse hiring runs through staffing agencies whose own offices were closed or remote.

OP, office and administration

Billing, safety, compliance (IRP, IFTA and UCR filings), claims and customer service ran from offices the telework and occupancy orders reached, and filed with State agencies whose counters were closed.14

WF, workforce availability

Drivers and dock labor are hourly and cannot telework. The school and child-care closures of 2020, the paid-leave mandate of the Families First Coronavirus Response Act from April 1 to December 31, 2020, the State quarantine and isolation orders that removed exposed workers from every floor for ten to fourteen days, the transit agencies' face-covering and service-reduction rules on every commute (the former an airborne-transmission control made a condition of riding) and the school masking and quarantine orders of the 2021-22 year reached the workforce by law.15

CB, the customer base

The customer base consists of shippers (manufacturers, importers, growers, distributors) and receivers (retail distribution centers and stores, restaurants and foodservice, hospitals, construction sites, plants, e-commerce fulfillment) in every industry, whose closures, caps and reopening steps are the customer-side orders of the layers and quarters below. A foodservice distributor's customer base was closed to dine-in service in every State between March 15 and April 3, 2020, the great majority by March 24; a building-materials wholesaler's customer base was shut in Pennsylvania, New York, New Jersey, Michigan, Washington, Boston and the Bay Area; a beauty-supply distributor's customer base was closed for two to three months in every State; an event-services logistics firm's customer base was closed by order for a year.16

Counterparties and supply chain

The counterparties are shippers and receivers; brokers and third-party logistics providers; ports, terminal operators, ocean carriers, railroads and air-cargo handlers; truck stops, rest areas and toll authorities; OEM dealers and parts suppliers; fuel suppliers; insurers and lessors; motor-vehicle agencies, IRP and IFTA offices and weigh stations; FMCSA, CBP, the Coast Guard, FRA, TSA, OSHA and the State OSHA programs; CDL schools and third-party examiners; drug-testing consortia and collection sites; staffing agencies; and industrial landlords. Tractors and trailers came from Class 8 plants idled from March to May 2020; parts and tires from Michigan, Ohio, Indiana, Mexico, China and Southeast Asia; personal protective equipment and sanitizer under federal allocation orders and the Department of Health and Human Services' scarce-materials designation; and wholesale inventories from domestic plants under State closures and from imports under the entry proclamations, land-border notices, port congestion and foreign lockdowns.17

Seasonality

The industry's peaks are the retail build (September to December), produce seasons (February to October by region), the construction season (April to November), back-to-school (July and August), beverage (May to September) and year-end inventory. The customer-side orders fell across every peak of 2020 (the spring closures, the summer capacity caps, the winter re-closures), and the Delta-wave orders fell across the 2021 retail peak build.

  1. Bureau of Labor Statistics, Industries at a Glance: Truck Transportation (NAICS 484); Warehousing and Storage (NAICS 493); Wholesale Trade (NAICS 42); Support Activities for Transportation (NAICS 488) (read Sept. 26, 2026) (employment as of Aug. 2026; establishments as of Q1 2026; occupational employment as of 2025). The figures describe the industry's structure and are stated as context; no 2020 or 2021 revenue or tonnage figure is asserted on this page. ↩
  2. American Trucking Associations, Economics and Industry Data (Ex. SEC-11-093). ↩
  3. U.S. Census Bureau, Monthly Wholesale Trade: Sales and Inventories (kind-of-business categories); Governor of Pennsylvania, Order Regarding the Closure of All Businesses That Are Not Life Sustaining, with the Industry Operation Guidance list (Mar. 19, 2020) (Ex. SEC-11-021). ↩
  4. CISA, Guidance on the Essential Critical Infrastructure Workforce (Mar. 19, 2020) (Ex. FED-394); id., Version 3.0 (Apr. 17, 2020) (Ex. SEC-07-003); the representative State incorporations are cited in the closure-layer note below. The guidance describes itself as "advisory in nature"; it acquired force through the State orders that adopted it, and each of those orders is a governmental order. ↩
  5. Executive Order No. 202.6 (N.Y. Mar. 18, 2020); Executive Order No. 107 ¶¶ 10-11 (N.J. Mar. 21, 2020) (Ex. SEC-10-023); Order of the Secretary of the Pennsylvania Department of Health for Mitigation and Enforcement § 6 (Nov. 23, 2020; effective Nov. 27, 2020) (Ex. PA-022); MIOSHA Emergency Rules, Coronavirus Disease 2019 (COVID-19), R. 5(8) (Oct. 14, 2020), as restated in Wayne County Health Officer, Updated Emergency Public Health Order (Oct. 16, 2020) (Ex. MET-DET-032) ("an employer shall create a policy prohibiting in-person work for employees to the extent that their work activities can feasibly be completed remotely"); see Ex. AGY-ST-LABOR-WORKPLACE-049 (MIOSHA presentation of the rules; secondary exhibit). ↩
  6. Ex. SEC-11-055 (Vermont Addendum 7, Mar. 30, 2020); Ex. SEC-11-054 (Maine Executive Order 34 FY 19/20, Apr. 3, 2020) ("all lodging operations and accommodations shall close except to the extent of providing lodging for the purposes stated below"); Pennsylvania Turnpike Commission, closure of all seventeen service plazas (Mar. 17, 2020) and reopening with restrooms and limited take-out food only (Mar. 19-20, 2020) (Ex. AGY-AVIATION-SURFACE-053); the dine-in closure orders are collected in the State layer below. ↩
  7. Ex. SEC-11-044 (Texas GA-12), Ex. SEC-11-040 (Florida EO 20-86), Ex. SEC-11-041 (Florida EO 20-82), Ex. SEC-11-048 (New York EO 205), Ex. SEC-11-049 (Connecticut EO 7III), Ex. SEC-11-046 (Pennsylvania travel order), Ex. SEC-11-047 (Alaska Health Mandate 010) (secondary exhibit), Ex. SEC-11-054, Ex. SEC-11-055, Ex. SEC-11-059 (New Mexico EO 2020-054) (secondary exhibit); COVID-19 Order No. 45 (Mass. July 24, 2020) (Ex. MA-025); Ex. FED-216 to Ex. FED-236 and Ex. FED-239 to Ex. FED-259 (the land-border series). ↩
  8. 86 Fed. Reg. 8025 (Feb. 3, 2021) (Ex. FED-020). ↩
  9. Ex. SEC-11-020 (N.J. Executive Order No. 122); Ex. SEC-11-022 (New York State Department of Health, Interim Guidance for Wholesale Trade); Ohio Department of Health, Manufacturing, Distribution & Construction sector requirements (published Apr. 27, 2020; mandatory with the Stay Safe Ohio Order from May 4, 2020) (Ex. SEC-11-030); Director's Stay Safe Ohio Order (Apr. 30, 2020) (Ex. OH-019); Minnesota Emergency Executive Order 20-40 (Apr. 23, 2020) (Ex. MN-015; Ex. SEC-10-044) and 20-56 (May 13, 2020) (Ex. SEC-10-045); Pennsylvania Secretary of Health, Worker Safety Order (Apr. 15, 2020; effective Apr. 19, 2020); Cal. Code Regs. tit. 8, § 3205 (Ex. SEC-11-027); 16VAC25-220 (Ex. SEC-10-042); Ex. AGY-ST-LABOR-WORKPLACE-049 (MIOSHA); Wash. Admin. Code § 296-800-14035 (Ex. AGY-ST-LABOR-WORKPLACE-050); OSHA DIR 2021-03, App. A (Ex. FED-083). ↩
  10. Michigan Executive Order 2020-21 (Mar. 23, 2020) and 2020-42 (Apr. 9, 2020) (Ex. SEC-07-022); Ohio Amended Director's Stay At Home Order (Apr. 2, 2020) (Ex. OH-014); Indiana Executive Order 20-08 (Mar. 23, 2020); New Jersey Motor Vehicle Commission notice (agencies, road testing and inspection facilities closed from Mar. 16, 2020; reopened July 7, 2020) (Ex. AGY-ST-DMV-SOS-RECORDERS-019). ↩
  11. The receiving-side orders are the customer-side orders of the layers and quarters below; for health-care receivers, see Executive Order 2020-21 § 8 (Mich.) and Dallas County Judge, Supplemental Order on Continuing Requirements after Expiration of Stay Home, Stay Safe, ¶ 1(f)-(g) (Aug. 4, 2020) (Ex. MET-DFW-024) (¶ 1(f): a household with a positive case "is ordered to isolate at home" and its members "cannot go to work"; ¶ 1(g): nursing, retirement and long-term care facilities "to prohibit non-essential visitors from accessing their facilities"; ¶ 1(e) suspended local delivery-hour restrictions on transport of food, medicine and medical supplies for sixty days). ↩
  12. Ex. AGY-USCG-PORTS-011 (MSIB 10-20, Mar. 27, 2020), Ex. AGY-USCG-PORTS-021 (MSIB 07-20 Ch. 2, May 7, 2020), Ex. AGY-USCG-PORTS-028 (MSIB 08-20 Ch. 5, Dec. 22, 2020), Ex. AGY-USCG-PORTS-031 (MSIB 02-21, Feb. 1, 2021), Ex. AGY-USCG-PORTS-032 (MSIB 04-21, Mar. 17, 2021), Ex. AGY-USCG-PORTS-033 (MSIB 02-21 Ch. 1, Mar. 22, 2021), Ex. AGY-USCG-PORTS-034 (MSIB 13-20 Ch. 3, Apr. 21, 2021), Ex. AGY-USCG-PORTS-035 (MSIB 02-20 Ch. 7, May 5, 2021), Ex. AGY-USCG-PORTS-037 (MSIB 02-21 Ch. 2, June 11, 2021), Ex. AGY-USCG-PORTS-038 (MSIB 02-21 Ch. 3, Sept. 2, 2021); Ex. AGY-AVIATION-SURFACE-014 (FRA Emergency Order No. 32); Ex. AGY-AVIATION-SURFACE-025, Ex. AGY-AVIATION-SURFACE-021, Ex. AGY-AVIATION-SURFACE-022 (FAA Exemptions 18584, 18561B and 18584A); Ex. FED-020. The Coast Guard's bulletins are classified as context in the Library's agency records and are cited as evidence of the maritime regime; the orders are Ex. FED-020 and the Captains of the Port's orders under 33 C.F.R. § 160.111, with the reporting and facility-security regulations of 33 C.F.R. §§ 160.216 and 105.125. ↩
  13. Ex. AGY-ST-DMV-SOS-RECORDERS-002 (Indiana BMV, Mar. 23, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-007 (Wisconsin DMV, Mar. 19-20, 2020: all centers closed; skills tests cancelled), Ex. AGY-ST-DMV-SOS-RECORDERS-012 (California DMV enforcement discretion from Mar. 16, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-018 (California DMV field offices closed Mar. 27, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-019 (New Jersey MVC closed from Mar. 16, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-022 (Tennessee driver services centers limited; skills tests suspended to May 18, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-026 (South Carolina, Mar. 26, 2020), Ex. AGY-ST-DMV-SOS-RECORDERS-097 (Louisiana OMV statewide closure), Ex. AGY-ST-DMV-SOS-RECORDERS-099 (Alabama ALEA offices closed until further notice); DOT ODAPC, Statement of Enforcement Discretion (Apr. 4, 2020) (Ex. AGY-AVIATION-SURFACE-045), as updated May 27, 2021 (effective through Dec. 31, 2021) (Ex. AGY-AVIATION-SURFACE-046); FMCSA, Notice, Agency Information Collection Activities (Dec. 14, 2020) (Ex. SEC-11-061) ("the ongoing COVID-19 situation, which has impacted SDLAs and their operating statuses"). The motor-vehicle agencies' notices and the Department's statements are classified as context in the Library's agency records and are cited as evidence of the closures, suspensions and extensions they record, not as orders. ↩
  14. The State layer below (the telework mandates) and Ex. AGY-ST-DMV-SOS-RECORDERS-021 (New Jersey MVC extensions and CDL FAQ, Oct. 1, 2020). ↩
  15. Families First Coronavirus Response Act, Pub. L. 116-127, 134 Stat. 178 (Mar. 18, 2020) (Ex. ECO-B-001); 29 C.F.R. pt. 826, 85 Fed. Reg. 19326 (Apr. 6, 2020) (Ex. ECO-B-002); Ex. FED-020 (transit); San Diego County Health Officer, Quarantine Order (Apr. 5, 2021; rev. July 22, 2021) (Ex. MET-SAN-024) and Isolation Order (Dec. 24, 2020) (Ex. MET-SAN-023); Riverside County, Protocol for Critical Infrastructure Workers (Feb. 17, 2021) (Ex. MET-RIV-017); the school orders in the third-quarter inventory below. ↩
  16. The customer-side orders are collected in the companion analyses on this site: Restaurants and Food Service, Retail Trade, Construction, Manufacturing, Personal Care and Other Services, Fitness, Arts, Entertainment and Sports and Weddings, Events and Production Services; the lead instruments are cited in the State layer below. ↩
  17. Executive Orders 13909, 13910 and 13911 (Mar. 18, 23 and 27, 2020) (Ex. FED-070, Ex. FED-071, Ex. FED-072); Executive Order 13917 (Apr. 28, 2020) (Ex. FED-073); HHS, Notice of Designation of Scarce Materials or Threatened Materials Subject to COVID-19 Hoarding Prevention Measures (Mar. 25, 2020) (Ex. FED-074), as extended July 7, 2021 to Nov. 15, 2021 (Ex. ECO-A-071); FEMA, Prioritization and Allocation of Certain Scarce or Threatened Health and Medical Resources for Domestic Use, 44 C.F.R. pt. 328 (Apr. 7, 2020) (Ex. FED-075); Ex. FED-207, Ex. FED-208 (entry proclamations); Ex. FED-216 to Ex. FED-259 (land borders). ↩