20th March 2020
Subject: Coronavirus (COVID-19) Continued Operations
To Whom It May Concern:
Since the situation around COVID-19 began to develop earlier this year, all TriMas Aerospace companies have put strong measures in place to help prevent the spread of the Coronavirus, protect the health of our employees, customers and suppliers as well as the communities in which we conduct business to ensure business continuity.
Recently, there has been some confusion about which businesses may continue to operate in response to advice, requests and/or orders from various federal, state and local authorities designed to curb the spread of COVID-19. We are continuing to monitor the situation and are keeping apprised of relevant guidance on a real time basis.
As of this communication, TriMas Aerospace businesses including MONOGRAM AEROSPACE FASTENERS, ALLFAST FASTENING SYSTEMS, MAC FASTENERS, MARTINIC ENGINEERING AND RSA ENGINEERED PRODUCTS have not been requested, ordered or advised to halt operations under California’s statewide “Shelter in Place” order, as its work has been deemed important to Californians’ health and well-being. As a result, we intend to continue operating, in accordance with applicable law and recommended best practices designed to ensure the safety of our employees, customers, suppliers and the community at large.
Executive Order N-33-20, signed by California Governor Gavin Newsom on March 19, 2020 (the “Shelter in Place” order, available online at https://covid19.ca.gov/img/N-33-20.pdf), orders that, subject to certain limited exceptions, all individuals living in the State of California “stay home or at their place of residence except as needed to maintain continuity of operations of the federal critical infrastructure sectors, as outlined at https://www.cisa.gov/critical-infrastructure-sectors.”
The Shelter in Place order further clarifies that the 16 critical infrastructure sectors identified by the federal government “are considered so vital to the United States that their incapacitation or destruction would have a debilitating effect on security, economic security, public health or safety, or any combination thereof.” Accordingly, the Shelter in Place order directs that “Californians working in these 16 critical infrastructure sectors may continue their work because of the importance of these sectors to Californians’ health and well-being.”
All TriMas Aerospace business operations fall within those 16 critical infrastructure sectors, specifically including the “Critical Manufacturing Sector,” which is defined to include “Aerospace Products and Parts Manufacturing” (see https://www.cisa.gov/critical-manufacturing-sector) and the “Defense Industrial Base Sector” which is defined as “the worldwide industrial complex that enables research and development, as well as design, production, delivery, and maintenance of military weapons systems, subsystems, and components or parts, to meet U.S. military requirements. The Defense Industrial Base partnership consists of Department of Defense components, more than 100,000 Defense Industrial Base companies and their subcontractors who perform under contract to the Department of Defense, companies providing incidental materials and services to the Department of Defense, and government-owned/contractor-operated and government-owned/government-operated facilities (see https://www.cisa.gov/defense-industrial-base-sector).
Accordingly, all TriMas Aerospace business units will continue to operate consistent with the terms of the “Shelter in Place” order. Our California business units are NOT required to halt activities under the Los Angeles County “Safer at Home” Order because it performs “essential activities” as defined therein.
In addition to the “Shelter in Place” order, most areas of Los Angeles County are subject to the terms of the Los Angeles County Department of Public Health’s March 19, 2020 “Safer at Home Order for the Control of COVID-19” (the “Safer at Home” order, available online at: http://publichealth.lacounty.gov/media/Coronavirus/COVID19_SaferAtHome_HealthOfficerOrder_20200319_Signed.pdf).
The Safer at Home order requires that certain businesses temporarily shut down, but provides exemptions for defined “Essential Businesses,” from that requirement. “Essential Businesses” under the Safer at Home order include:
Para 13(p): Airlines
Para 13(n): Businesses that supply other Essential Businesses with the support or supplies necessary to operate
Para 13(q): Businesses that provide parts and service for “Essential Infrastructure” (which includes, “airport operations . . . . and manufacturing and distribution operations deemed essential as part of the Essential Infrastructure supply chain; provided that they carry out those services or that work in accordance with social distancing requirements, to the extent practicable” (¶ 15 (b)(ii)); and
Para 13(u): Military/Defense Contractors. For purposes of the Safer at Home order, “essential personnel may leave their residence to provide any service or perform any work deemed essential for national security including, but not limited to defense, intelligence and aerospace development and manufacturing for the Department of Defense…Essential personnel include prime, sub-primes and supplier contractor employees, at both the prime contract level and any supplier levels at any tier, working on federal United States Government contracts such as contracts rated under the Defense Priorities and Allocations System (DPAS) and contracts for national intelligence and national security requirements.”
All TriMas Aerospace business units are manufacturing aerospace product for use by other “Essential Businesses,” including for “Essential Infrastructure” and for use on projects governed by federal United States Government Contracts. As those terms are defined under the “Safer at Home” order, each of our business units classify as an “Essential Business” and will continue to operate consistent with the “Safer at Home” order.
In maintaining our business operations, the continued health and safety of our employees, customers, suppliers and the community at large continues to be our first priority. Should you have any questions or require additional information, please do not hesitate to contact me.