By Chuck White, Vice President of Regulatory Affairs
PHCC—National Association has filed a request with the Department of Homeland Security (DHS) to clarify its definition for workers that would be classified as providing essential services. DHS has issued a Memorandum that contains the following language pertaining to residential services in the Public Works section.
Workers such as plumbers, electricians, exterminators, and other service providers who provide services that are necessary to maintaining the safety, sanitation, and essential operation of residences.
The DHS document clearly indicates plumbing is included but is less clear on HVAC service; a strong case could be made that it would be included as “services that are necessary to maintaining … essential operation of residences.” DHS needs to make this distinction in its Cybersecurity and Infrastructure Security Agency (CISA) guidance as more states begin to issue stay-at-home quarantine orders, therefore PHCC sent this letter to DHS on behalf of the p-h-c industry.
While current guidance comes from the federal government, implementation will occur at the state and local level. Contractors will need to verify local compliance requirements for providing essential services. Some items to consider could include:
- Contact local enforcement agencies to determine the business status as essential.
- Ensure technicians have any license documentation available for review.
- Provide work orders for use as supporting evidence.
- Use company service vehicles with appropriate signage when possible.
- Provide evidence of PPE and protocols for client interactions.
The country and the industry find themselves in uncharted waters. Please be aware that most enforcement activity will be conducted locally and is dependent upon the severity of local conditions. Communication is key … reach out to local authorities to stay on the right side of the law; limit activities to maintaining services that are truly essential; and be prepared for the rules to change with minimal notice. Lastly, stay safe out there.
Vice President of Regulatory Affairs , PHCC-National Association