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The COVID Project

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

The inputs and counterparties

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).

  1. Bureau of Labor Statistics, Industries at a Glance: Personal and Laundry Services: NAICS 812; Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019-2021 annual averages, private ownership, national, NAICS 8121, 8122, 8123, 8129 and 8114; National Funeral Directors Association, Statistics (nfda.org/news/statistics). ↩
  2. CARES Act § 2301(c)(2)(A)(ii)(I), Pub. L. 116-136, 134 Stat. 281, 347-48 (2020) (Ex. LAW-001); I.R.C. § 3134(c)(2)(A)(ii)(I) (Ex. LAW-354); Tri-State Memorial Hospital v. United States, No. 2:25-cv-0181-TOR, ECF No. 38, at 9 (E.D. Wash. May 28, 2026) ("Tri-State") ("a 'partial suspension' is a temporary delay, interruption, or termination of a portion an employer's business"). The statute is read element by element on the statute page of this site. ↩
  3. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 812111 (barber shops), 812112 (beauty salons) and 812113 (nail salons). ↩
  4. See the fifty States and the largest metros in the layers section and SL in the function-by-function section; Governor of Texas, Executive Order GA-21, ¶ 12.a (May 5, 2020) (Ex. SEC-18-025); Commonwealth of Kentucky, Healthy at Work Requirements for Barbers/Cosmetologists/Hair Salons, Version 2.0 (June 25, 2020) (Ex. SEC-18-039); Illinois Department of Commerce and Economic Opportunity, Restore Illinois Phase 4 Personal Care Services Guidelines (June 22, 2020) (Ex. SEC-18-018); Mayor of New York City, Emergency Executive Order No. 130, s. 3 (July 7, 2020) (Ex. MET-NYC-025); Governor of Arizona, Executive Order 2020-34 (May 4, 2020) (Ex. AZ-017); Mayor of the District of Columbia, Mayor's Order 2020-067 (May 27, 2020) (Ex. DC-029); Johnson County Board of Public Health, Order No. 002-20 (Nov. 13, 2020) (Ex. MET-KC-061). ↩
  5. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 8123, 812310 (coin-operated laundries and drycleaners) and 812320 (drycleaning and laundry services, except coin-operated). ↩
  6. Cybersecurity and Infrastructure Security Agency, Guidance on the Essential Critical Infrastructure Workforce, Version 3.0 (Apr. 17, 2020) (Ex. SEC-18-002); Version 1.0 (Mar. 19, 2020) (Ex. FED-394); Version 4.1 (Aug. 10, 2021) (Ex. SEC-18-001); Governor of New Jersey, Executive Order No. 107, ¶ 6.i (Mar. 21, 2020) (Ex. SEC-18-008); Governor of Illinois, Executive Order 2020-10, § 12.w (Mar. 20, 2020) (Ex. SEC-18-032). ↩
  7. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2020 and 2021 annual averages, private ownership, national, NAICS 8123 and 812320. ↩
  8. Occupational Exposure to COVID-19; Emergency Temporary Standard, 29 C.F.R. § 1910.502, 86 Fed. Reg. 32376 (June 21, 2021) (Ex. FED-080); Occupational Safety and Health Administration, COVID-19 Healthcare ETS Frequently Asked Questions (scope) (June 2021) (Ex. SEC-18-004) (healthcare laundry services performed in healthcare settings covered; off-site laundry excluded). ↩
  9. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 8122 and 812210; National Funeral Directors Association, Statistics (nfda.org/news/statistics). ↩
  10. Wisconsin Department of Health Services, Emergency Order #12, Safer at Home Order, § 13.h-i (Mar. 24, 2020) (Ex. SEC-18-034); Governor of Illinois, Executive Order 2020-10, § 12.w (Ex. SEC-18-032); Governor of New York, Executive Order No. 202.10 (Mar. 23, 2020) (Ex. NY-005) (non-essential gatherings of any size); Commonwealth of Kentucky, Healthy at Work Requirements for Funeral and Memorial Services, Version 2.0 (May 22, 2020) (Ex. SEC-18-041); Governor of Louisiana, Proclamation 38 JBE 2020 (Mar. 31, 2020) (Ex. LA-006) (funeral services and interments); Michigan Department of Health and Human Services, Emergency Order, COVID-19 Death Reporting (Apr. 4, 2020) (Ex. AGY-ST-HEALTH-SUBORDERS-094) and Emergency Order, Handling of Bodily Remains (May 4, 2020) (Ex. AGY-ST-HEALTH-SUBORDERS-095); New Jersey Department of Health, Executive Directive No. 20-010 (Revised), Disposition of Remains (Aug. 20, 2020) (Ex. AGY-ST-HEALTH-SUBORDERS-029); Governor of Delaware, Fourth Revision of the Twenty-Seventh Modification (Omnibus) of the Declaration of a State of Emergency (Dec. 10, 2020; effective Dec. 14, 2020) (Ex. DE-033) (indoor gatherings, including funerals, the lesser of 30 percent or 50); Pennsylvania Department of State, Temporary Waiver of Rule for Funeral Home Directors (Mar. 30, 2020) (Ex. PA-095). ↩
  11. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2020 annual averages, private ownership, national, NAICS 8122. ↩
  12. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 812910. ↩
  13. Cybersecurity and Infrastructure Security Agency, Guidance on the Essential Critical Infrastructure Workforce, Versions 3.0 and 4.1 (Ex. SEC-18-002; Ex. SEC-18-001); Oklahoma, Open Up and Recover Safely Plan, Phase 1 (Apr. 22, 2020) (Ex. OK-021) and Fourth Amended Executive Order 2020-13 (Apr. 24, 2020) (Ex. OK-022); Commonwealth of Kentucky, Healthy at Work Requirements for Pet Care, Grooming, and Boarding Businesses, Version 1.0 (May 11, 2020) (Ex. SEC-18-040); New Mexico Department of Health, Amended Public Health Emergency Order of November 18, 2020 (Ex. NM-040) (animal grooming closed in the reset). ↩
  14. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 8114. ↩
  15. Cybersecurity and Infrastructure Security Agency, Guidance on the Essential Critical Infrastructure Workforce, Version 3.0 (Ex. SEC-18-002); Governor of Michigan, Executive Order 2020-42, § 9 (Apr. 9, 2020); Michigan Department of Labor and Economic Opportunity, COVID-19 Workplace Guidelines for In-Home Services (June 9, 2020) (Ex. SEC-18-015); Detroit Health Department, Emergency Order for Control of Epidemic, at 12 (Oct. 9, 2020) (Ex. MET-DET-001); Governor of New York, Executive Order No. 202.8 (Mar. 20, 2020) (Ex. NY-002); Governor of New Jersey, Executive Order No. 107 (Ex. SEC-18-008); Governor of California, Executive Order N-33-20 (Mar. 19, 2020). ↩
  16. See the fifty States in the layers section and RT in the function-by-function section; e.g., Governor of Texas, Executive Order GA-14 (Mar. 31, 2020) (Ex. SEC-18-033); Dallas County Judge, Rules for Reopened Services (Apr. 23, 2020) (Ex. MET-DFW-016) ("Customers may not enter the premises"); San Francisco Health Officer, Order No. C19-07d (May 17, 2020) (Ex. MET-SFO-016) (curbside retail from May 18, 2020). ↩
  17. Texas Department of Licensing and Regulation, COVID-19 Information Page (updates Mar. 13 to Oct. 13, 2020) (Ex. AGY-ST-TRADE-BOARDS-009) (the Department's announcement of the Governor's waivers and office closures, cited as context); Florida Department of Business and Professional Regulation, Information for Barbershops, Cosmetology Salons, and Cosmetology Specialty Salons pursuant to Executive Order 20-120 (May 9, 2020) (Ex. AGY-ST-TRADE-BOARDS-002); Virginia Department of Professional and Occupational Regulation, Temporary Waiver of Regulations that Prohibit or Limit Online, Electronic, or Distance Theoretical Instruction (Mar. 13, 2020; amended May 27, 2020) (Ex. AGY-ST-TRADE-BOARDS-024) and Board for Barbers and Cosmetology, Resources for Licensees during COVID-19 Outbreak (Mar. 23, 2020) (Ex. AGY-ST-TRADE-BOARDS-025); Illinois Department of Financial and Professional Regulation, Measures to Assist Licensees and Education Providers (Mar. 18, 2020) (Ex. AGY-ST-TRADE-BOARDS-053); California Department of Consumer Affairs, Waivers DCA-20-54 (Sept. 3, 2020), DCA-20-70 (Oct. 22, 2020), DCA-21-135 (Mar. 30, 2021), DCA-21-153 (June 3, 2021), DCA-21-176 (July 2021) and DCA-21-195 (Sept. 28, 2021) (Ex. AGY-ST-TRADE-BOARDS-045; Ex. AGY-ST-TRADE-BOARDS-048; Ex. AGY-ST-TRADE-BOARDS-049; Ex. AGY-ST-TRADE-BOARDS-050; Ex. AGY-ST-TRADE-BOARDS-051; Ex. AGY-ST-TRADE-BOARDS-052) (Division 3 licensees, including barbering and cosmetology and funeral directors and embalmers); Pennsylvania Department of State, Regulation Waiver - Barbers and Cosmetologists (Mar. 26, 2020) (Ex. PA-094) and Regulation Waiver - Funeral Directors (Mar. 30, 2020) (Ex. PA-095), continued by Act 21 of 2021 to Sept. 30, 2021. ↩
  18. Commonwealth of Kentucky, Healthy at Work Requirements for Barbers/Cosmetologists/Hair Salons, Version 2.0 (Ex. SEC-18-039); Illinois DCEO, Phase 4 Personal Care Services Guidelines (Ex. SEC-18-018); Governor of Minnesota, Emergency Executive Order 20-63 (May 27, 2020) (Ex. MN-024); Governor of Oregon, Executive Order 20-12 (Mar. 23, 2020) (Ex. OR-007); Secretary of the Pennsylvania Department of Health, Order for Mitigation and Enforcement (Nov. 23, 2020) (Ex. PA-022); Governor of Illinois, Executive Order 2020-73 (Nov. 18, 2020) (Ex. SEC-18-019). ↩
  19. Families First Coronavirus Response Act, Pub. L. 116-127, 134 Stat. 178 (Mar. 18, 2020) (Ex. FED-170); 29 C.F.R. part 826, 85 Fed. Reg. 19326 (Apr. 6, 2020) (Ex. FED-171); 85 Fed. Reg. 57677 (Sept. 16, 2020) (Ex. FED-172); Centers for Disease Control and Prevention, Requirement for Persons To Wear Masks While on Conveyances and at Transportation Hubs, 86 Fed. Reg. 8025 (Feb. 3, 2021) (Ex. FED-020); see the counterparties in the layers section for the school and quarantine orders. ↩
  20. Governor of Texas, Executive Order GA-14 (Mar. 31, 2020) (Ex. SEC-18-033); Notice 2021-20, 2021-11 I.R.B. 922, Q&A-10, at 928 (the shelter-in-place proclamation and the curfew as governmental orders). ↩
  21. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 8121 and 8122 (average weekly wages). ↩
  22. California Department of Public Health, State Public Health Officer Order of July 13, 2020 (Ex. SEC-18-022) (indoor malls); Notice of Designation of Scarce Materials or Threatened Materials Subject to COVID-19 Hoarding Prevention Measures, 85 Fed. Reg. 17592 (Mar. 25, 2020) (Ex. FED-074); Extension of Designation (Feb. 1, 2021) (Ex. ECO-A-070); Extension of Designation to Nov. 15, 2021 (July 7, 2021) (Ex. ECO-A-071); Centers for Medicare & Medicaid Services, QSO-20-39-NH REVISED, Nursing Home Visitation - COVID-19 (Apr. 27, 2021) (Ex. FED-156). ↩
  23. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 and 2020 annual averages, private ownership, national, NAICS 8121. ↩
  24. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, 2019 annual averages, private ownership, national, NAICS 8121 and 8123 (establishment counts). ↩