Vaccine and Reopening Resources

On January 12th, Code Council CEO Dominic Sims sent a letter to the Centers for Disease Control (CDC) urging the classification of code officials as frontline essential workers. This action is aimed at aligning CDC COVID-19 vaccine guidelines and priorities with standing guidance from the U.S. Department of Homeland Security (DHS) designating code officials as members of the nation’s Essential Critical Infrastructure Workforce. The letter to CDC is the latest step in the Code Council’s broader effort to ensure code officials continue to be recognized for their critical role in building safety.

Additional information on CDC’s vaccine rollout recommendations, code official eligibility, and state actions are included below.

Phased Rollout of the COVID-19 Vaccine

The first COVID-19 vaccines were authorized for emergency use by the Food and Drug Administration in early December 2020. The CDC’s Advisory Committee on Immunization Practices (ACIP) recommended healthcare personnel and long-term care facility residents be the first to receive the vaccine under Phase 1a of the rollout. An important note is that states and territories are ultimately responsible for developing their specific plans, policies, and procedures for administering the COVID-19 vaccine.

On December 20th the CDC updated its COVID-19 vaccine recommendations adding Phase 1b and Phase 1c.

Phase 1b - Currently includes persons 75 years and older and non-health care frontline essential workers (first responders, corrections officers, food and agricultural workers, U.S. Postal Service workers, manufacturing workers, grocery store workers, public transit workers, education workers and childcare workers).

Phase 1c - Currently includes persons aged 65–74, persons aged 16–64 years with high-risk medical conditions, and essential workers not included in Phase 1b.

Code Official Eligibility for the COVID-19 Vaccine

In January, CDC published a crosswalk connecting standardized industry codes and titles (e.g., NAICS Codes) to DHS’s Essential Critical Infrastructure Workforce recommendations and CDC’s recommendations for vaccination in Phases 1a, 1b, and 1c. While DHS’s guidance clearly recognizes code officials as members of the Essential Critical Infrastructure Workforce, CDC’s crosswalk is not as clear with regard to clarifying vaccine priorities. From our read of the crosswalk:

  • There is a strong case to be made that certain code officials, particularly those working on-site or in the field, should receive the vaccine during Phase 1b as members of the CDC category under NAICS Code 92219 - Other Justice, Public Order, and Safety Activities.
  • CDC’s guidance recommends fire prevention officials receive the vaccine during Phase 1b and substantively covers this group as first responders under NAICS code 92216 - Fire Protection.
  • Other code officials not working on-site or in the field are recommended to receive the vaccine during Phase 1c.

States make the Ultimate Decision

Importantly, while they may choose to adhere to CDC’s recommendations, the ultimate decision on vaccine distribution rests with states. For a complete listing of state and territory COVID-19 vaccine information, please visit the National Governors Association State COVID-19 Vaccine Resources page.

Talking points supporting state recognition of code officials as frontline and essential workers for COVID-19 vaccine distribution are available here.