How a personal care or other services business operates
This is an industry of small, licensed, appointment-driven service premises whose product is delivered within arm's length of the customer, whose workforce is hourly, commissioned or booth-renting and predominantly female, and whose commercial lines (linen and uniform accounts, funeral repasts, retail products) depend on hotels, restaurants, hospitals, schools and events. The orders that named the trade reached the service itself; the orders on its customers, its landlords, its suppliers, its licensing boards, its workforce's schools and its workforce's commute reached everything else. Each function below is stated in the operational terms an order can reach: what happens, where, with whom, and on what inputs.1
The functions
The industry's operations are coded as follows, and the codes are used throughout this page. The Suspension Clause asks whether "the operation of the trade or business" was fully or partially suspended, and a partial suspension is "a temporary delay, interruption, or termination of a portion an employer's business."2 The ten functions below are the portions.
SL: salon, barber, nail, skin, massage, tattoo and tanning services
The core function of NAICS 8121 is a licensed operator performing a service on a customer's hair, nails, skin or body, in a chair or on a table, on licensed premises, by appointment or on walk-in traffic, at a distance of inches, for twenty minutes to several hours, in a room shared with other operators and other customers who wait, converse and pay at a desk. A beauty salon averaged fewer than six employees in 2019 (421,585 employees across 74,418 establishments), a nail salon fewer than five and a barber shop about five; many stylists rent a chair and are paid by the customer.3 Every element of that description is an element an order can reach and did reach: the premises (closed by name in forty-six States and the District of Columbia); the chair (six feet from the next one under Texas Executive Order GA-21 ¶ 12.a); the walk-in (barred by appointment-only mandates in Arizona, Kentucky, Maryland, New Hampshire, the District, Michigan and the Kansas City counties); the waiting room (eliminated under Kentucky's requirements); the customer's face (covered by order, one of the workplace infection-prevention and exposure-control requirements of most States' reopening orders, so that lip, nose, facial and beard services were barred outright in Illinois, New York City, Chicago, Rhode Island, Alaska and Michigan and permitted only under eye protection in Illinois); the occupancy (twenty-five to fifty percent in Illinois, Kentucky, Connecticut, Massachusetts, New Jersey, Washington, Colorado, Louisiana, Minnesota, Pennsylvania, Philadelphia, Montgomery County and Denver); and the operator herself (bound in every reopened State by the exposure-control requirements of screening, sanitation, distancing and face covering, and, in the third quarter of 2021, placed under an indoor face-covering order again in seven States and the District).4
CL: laundry and dry cleaning
NAICS 8123 has three lines that the orders reached differently. Coin-operated laundromats (9,476 establishments) sell machine time to a retail customer who sits in the store; drop-off and route dry cleaners (18,976 establishments) clean the garments of office workers, wedding parties and travelers; and commercial and industrial laundries clean the linen and uniforms of hotels, restaurants, hospitals, nursing homes, salons, gyms, schools and events under volume contracts.5 Every version of the federal essential-workforce list named "[w]orkers in laundromats, laundry services, and dry cleaners," and every State that adopted the list left the laundromat open; the same States closed the hotel, the restaurant, the office, the wedding venue, the school and the gym whose linen and garments the laundry cleans, and confined the retail customer to her home.6 Employment in the subsector fell 18.0 percent in 2020 and the non-coin dry cleaners lost a quarter of their employment and 2,076 establishments by 2021.7 From June 21, 2021 a laundry performing services in a health-care setting was itself a covered workplace under the OSHA Healthcare Emergency Temporary Standard.8
FH: funeral homes, cemeteries and crematories
NAICS 8122 is 13,868 funeral homes and 4,416 cemeteries and crematories, about seventy-five percent family- or privately owned, employing 135,686 people.9 The at-need funeral is a sequence of operations each of which an order reached: removal of the decedent from a hospital or nursing home whose visitation was barred; embalming and preparation under State death-care rules that Michigan and New Jersey rewrote by emergency order; the viewing and the service, which are "group meetings" in the statute's words and which the orders capped at fewer than ten in Wisconsin, ten in Illinois, Michigan, New Jersey, Massachusetts, Delaware, Minnesota, Virginia, Kentucky and Kansas, barred as gatherings of any size in New York, and then capped at twenty-five to fifty percent through the winter of 2020-21 in New Jersey, Oregon, Delaware and Kentucky; the graveside committal under the same caps; the repast, which closed with the restaurants and reception halls; and the sale of caskets, vaults and pre-need contracts in an arrangement room that the customer was ordered not to visit.10 Death-care employment fell 4.3 percent in 2020 in a year in which the number of deaths in the United States rose.11
PS: pet grooming, daycare and boarding
NAICS 812910 (20,035 establishments; 137,133 employees) grooms, boards, trains and walks animals whose owners were ordered to stay home, to stop traveling and to work from their kitchens.12 Pet grooming appears in no version of the federal essential-workforce list; it closed with non-essential retail in every stay-home State and reopened on its own track (Oklahoma April 24, 2020; Colorado, Maine and West Virginia May 1-4; Kentucky May 11 under requirements a shop "must meet ... in order to reopen and remain open"; Massachusetts May 25) under curbside hand-off, appointment and face-covering conditions, the exposure-control terms of the reopening orders; New Mexico closed animal grooming again in its November 2020 reset.13 Boarding revenue follows travel, and travel was under order on every day of the period.
RP: in-home and shop repair
NAICS 8114 (22,721 establishments; 78,989 employees) repairs appliances, furniture, footwear, watches, garments and electronics in the shop and appliances, plumbing, heating and electrical systems in the customer's home.14 The federal list named "personal and household goods, repair, and maintenance" among essential functions, and the stay-home orders of Michigan, New York, New Jersey and California nonetheless barred technicians from entering homes for non-emergency work until May and June 2020; Michigan then issued binding workplace guidelines for in-home services on June 9, 2020, and Detroit's October 9, 2020 order wrote in-home-service rules into a city health order.15 Shop repair closed with non-essential retail.
RT: retail products
Salons sell professional hair, skin and nail products at the desk; laundries sell detergent and supplies; funeral homes sell caskets, urns and vaults; groomers sell food and supplies. The retail line closed with the sales floor between March 19 and April 3, 2020 and reopened under the retail caps, one-way aisles and curbside rules of each State.16
HR: hiring, licensing, examinations and schools
Every SL operator, funeral director and embalmer holds a State license issued on examination after schooling. The cosmetology and barber schools closed with the schools; the licensing boards closed their offices, suspended practical examinations and extended license terms by emergency order in Texas, Florida, Virginia, Illinois, California, Pennsylvania and Iowa; and the funeral boards did the same.17 An industry that could not examine or license new operators could not hire them.
OP: office, booking and administrative operations
Booking, payroll, pre-need sales, arrangement conferences and back-office work were ordered to remote operation where a State ordered telework (Kentucky's requirements: office staff "must continue to telework"; Illinois Phase 4: "[a]ll employees who can work from home should continue to do so"; Minnesota, Washington, Oregon and Pennsylvania) and were subject in every State to the workplace infection-prevention and exposure-control requirements of the reopening orders and workplace standards: screening, distancing, face coverings and sanitation, and in many States customer logs and record-keeping.18
WF: workforce availability
The 8121 workforce is predominantly women with school-age children; the laundry workforce commutes by transit in the cities; the funeral workforce is on call. School closures in the spring of 2020 and the remote fall of 2020, the school face-covering and quarantine orders of the 2021-22 year, the quarantine and isolation orders on exposed persons in every State, the federal leave mandate of April 1 through December 31, 2020, and the conveyance face-covering order, the federal airborne-transmission control on every bus and train from February 1, 2021, each fixed who could come to work and on what terms.19
CB: the customer base
The customer is a resident ordered to stay home, to avoid "visiting ... cosmetology salons," to wear a face covering indoors, to keep six feet from strangers and, if exposed, to quarantine; a traveler under quarantine; a bride whose wedding was capped; a family whose funeral was capped; a hotel, restaurant, office or school closed by order.20
The revenue lines
SL revenue is chair services plus retail; CL revenue is retail machine time, drop-off cleaning and commercial contracts priced by the pound and the piece; FH revenue is at-need services, merchandise and pre-need contracts; PS revenue is grooming appointments and boarding nights; RP revenue is service calls and shop repairs. Personal care services paid an average weekly wage of $498 in 2019 and death care $770; the margins are narrow and the fixed costs (rent, licenses, insurance, equipment) run whether the chair is occupied or not.21
Landlords and mall operators (the mall salon and the salon suite closed when California closed indoor malls on July 13, 2020); professional-beauty, casket, vault and chemical distributors and the plants that supply them (closed in Michigan, Pennsylvania, New York and New Jersey in March through May 2020); personal protective equipment, which the federal government designated a scarce material subject to allocation from March 25, 2020 to November 15, 2021; licensing boards and health inspectors; hospitals and nursing homes (as the funeral home's source of decedents, the commercial laundry's customer and the contract barber's place of work); cemeteries, crematories, clergy and churches; cosmetology schools; hotels, restaurants, offices, gyms and event venues (the laundry's accounts); and the transit systems, schools and child-care centers on which the workforce depends.22
The workforce
Licensed stylists, barbers, nail technicians, estheticians and massage therapists, many of them booth renters or commissioned; laundry production and route workers; licensed funeral directors and embalmers; groomers and kennel staff; repair technicians. The 8121 workforce is predominantly women; a quarter of the subsector's employment left in 2020.23
Seasonality and geography
Salons peak at prom, wedding and holiday seasons (April through June; November and December), which the 2020 orders closed and the 2020-21 winter orders re-capped; commercial laundries follow the hotel and event season; funeral homes carry a winter mortality peak; pet boarding peaks in summer travel. The industry is everywhere: 131,476 personal-care establishments and 31,255 laundry establishments are distributed with the population, so that the fifty-State and metropolitan tables on this page are not a sample but the industry's own map.24
The counterparty map
For each counterparty class, the orders that reached it are stated by category, with the subsection of the layers section that holds them: (a) the customer base: stay-home orders, gathering caps, face-covering orders (the airborne-transmission controls the States imposed on every indoor public place), travel quarantines and the "avoid ... cosmetology salons" directives of the States (the fifty States and the metros); (b) hotels, restaurants, offices, gyms, schools and venues as the laundry's accounts: the closure, capacity and hours orders on those sectors (the counterparties); (c) hospitals and nursing homes: visitation bans, vendor exclusions, testing and vaccination orders and the OSHA Healthcare Emergency Temporary Standard (the counterparties and the ecosystem); (d) landlords and malls: mall closures and eviction moratoria (the counterparties); (e) suppliers: plant closures, the Defense Production Act orders and the scarce-materials designations (the ecosystem); (f) licensing boards and schools: closure, examination and license-term orders (the sector regulators); (g) the workforce's schools, child care and transit: closure, remote-learning, face-covering, quarantine and conveyance orders (the counterparties and the ecosystem); and (h) courts and public offices: the judicial emergency orders under which estate, collection and licensing matters were heard remotely or not at all (the counterparties).