COVID-19 SHOOT/PRODUCTION GUIDELINES
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Our aim is to take reasonable and practical steps to provide a safe working environment throughout the production process and to deliver the highest quality creative content for our clients.
This document is a ‘back to work roadmap’, providing guidance and support about how we will assess and manage the risk of coronavirus (covid-19) in the production of photographic & film shoots.
Everyone involved in, or working on a shoot has a responsibility to take reasonable and practical steps in respect of covid-19.
This document should be read in conjunction with work place covid-19 guidance provided by the government and is based on industry specific advice from the UK Screen Alliance/British Film Commission/British Film Council/AOP/APA/BECTU/insurance companies etc.
Our guidance will be accompanied by policies from our suppliers and freelancers (where necessary).
These guidelines will be regularly updated in accordance with new government legislation, industry regulation & guidance as well as through our feedback loops and experience and available on our website.
KEY REQUIREMENT
Anyone on our producitons must fill in and sign our ‘Health Declaration’ and notify us immediately if they develop any symptoms (within 14 days before, or 14 days after the shoot).
We also encourage everyone to download and use the NHS app, if you haven’t already.
We have a legitimate interest in collecting this personal data to protect the health of our clients, employees, crew, and visitors. This information will be recorded and securely stored in accordance with our data protection / privacy policies. This information maybe used to track and trace in order to protect others and reduce the risk of shoot cancellations.
1. OUR COVID-19 COMMITMENT and training
We have undertaken specific training and become familiar with the risks of working with covid-19 and their mitigation. Our commitment to working safely is absolute, and we take the wellbeing of our crew and clients extremely seriously.
1.1 COMMITTMENT
Follow government guidance.
Follow industry specific guidelines, like the UK Screen Alliance/British Film Commission/British Film Council/AOP/APA/BECTU/insurance companies etc.
Follow advice from the health & safety executive or independent risk managers in relation to covid-19.
Not put any vulnerable people at risk.
Heighten precautions for everyone at work & on set.
Have a dedicated covid-19 risk manager throughout production.
Do risk assessments for all shoots (and locations) with additional attention being given to covid-19 (overview below to be amended as required).
Appropriate provision of ppe.
Reduce non-essential travel to/from locations, particularly if it is long distance, international or requiring public transport like tubes, trains or planes.
Allow & encourage crew/staff to work from home where possible.
Not insist that crew/staff work if they do not feel comfortable doing so.
Reduce the number of people involved on set.
Invite clients & crew (where possible) to use video conferencing platforms for the shoot and post production conversations, like q-take/zoom/facetime/houseparty and/or collaborative platforms like google drive/g suite/microsoft teams/dropbox.
Reduce & streamline locations, equipment requirements & suppliers.
Consider mental health and wellbeing.
Create a feedback loop.
1.2 OUR TRAINING
First Option Safety Consultants - Managing COVID-19 Risks on Productions
The Training Hub: Coronavirus Outbreak Specialist Online Course
APA: Covid-19 Supervisor
First Aid for Life: Emergency 1st Aid at Work with covid-19 bolt on
1.3 USEFUL LINKS
Staying COVID-19 Secure in 2020
Government regulation on Covid-19.
Government International Travel Guidance.
Health & Safety at Work Act 1974.
Government Social Distancing guidance.
NHS app for track and trace.
Industry specific guidelines: UK Screen Alliance/British Film Commission/British Film Council/AOP/APA/BECTU.
Staying Covid-19 Secure in 2020.
2. GOVERNMENT GUIDANCE (REVIEWED ON 15th MARCH 2022)
As of 24th February 2022 people who test positive for COVID are no longer legally required to self- isolate. Nor is someone who is a contact of someone with COVID required to take a COVID test or self-isolate. The guidance is the same as the law previously and these Guidelines require you to follow the guidance because it is the responsible course and the appropriate course in the context of your health and safety obligations as below: If you develop COVID-19 symptoms, self-isolate immediately and get a PCR test, even if your symptoms are mild.
People who test positive should stay at home and avoid contact with other people for at least 5 full days and continue to isolate until they have 2 negative tests 24 hours apart on consecutive days. So little has changed for those testing positive- COVID remains a live threat to productions and to the people working on them. You should still follow the same guidance and recommendations despite the legal change.
There is still Government COVID-19 guidance to follow through and as an employer, under the Health and Safety at Work etc. Act 1974, you continue to have a legal duty to ensure, so far as is reasonably practicable, the health, safety, and welfare of anyone who has contact with their business (employees, freelancers, contractors, members of the public etc.). The Management of Health and Safety at Work Regulations 1999 sit beneath this law and provide detail on what a safety management system should look like (e.g., how your business identifies and assesses its risks, takes steps to control them, trains relevant staff, and monitors/reviews its safety processes to ensure they are being carried out correctly andremain effective). The HSE has produced detailed guidance on this. Failure to comply with a business' health and safety duties is a criminal offence.
The purpose of this document is continuing to assist production companies to assess and manage their COVID-19 risks on shoots and identify reasonable and practical steps to safeguard the health and safety of everyone attending a film shoot in relation to COVID-19.
We have omitted much of the general guidance from the earlier version of these Guidelines because either it is no longer relevant, or it doesn’t require to be specifically highlighted and we want to ensure the new guidance is not lost in that detail.
The latest UK Government guidance on how businesses should control COVID-19 risks, as well as these Guidelines, should be considered (and relevant parts implemented) as you work through your business’ safety management procedure, particularly when carrying out your COVID-19 risk assessment.
In addition, everyone working on the production and attending it has responsibilities in respect of COVID-19. They can meet them by working in accordance with these Guidelines.
In applying this guidance, productions must:
- Consider how decisions and policies may affect people with different protected characteristics under the Equality Act 2010 and assess whether any further adjustments should be made in respect of such individuals. Productions are also advised to explore any concerns raised by cast or crew about attending the production, even in cases where protected characteristics do not appear to be relevant.
- Follow ICO guidance on storing data and testing. Ensure that the General Data Protection Regulation (GDPR) is observed, which will involve understanding suitable lawful bases, notifying people of any testing that is undertaken and completing a dataprotection impact assessment.
This document has been prepared in consultation with the Department for Digital, CultureMedia and Sport (DCMS) with input from APA members and in consultation with Public Health England (PHE) and the Health and Safety Executive (HSE). It will be updated regularly in response to feedback on how it works in practice, new Government law and regulation.
It is very important that you review UK Government updates in law and guidance so that your risk assessment and procedures are updated to reflect these changes. Please ensureyou are working from the latest guidance which is HERE.
NB: These guidelines are based on the law and guidance for filming in England. Productionsbased in Northern Ireland, Scotland and Wales should additionally check for the relevant devolved Government guidance as it may differ.
Productions should always be sensitive to local restrictions in place where you are filming. Ifso, you should first read the guidance relevant to that area as this may supersede guidance in this document.
3. APA GUIDELINES
The new Government guidelines recommend the following courses of action, and we recommend you follow those by taking these COVID measures (“the COVID measures”):
Carry out a COVID-19 risk assessment.
Clean more often -both of surfaces and in the provision of hand santiser and instructions to those attending the production to use it.
Wear face coverings whilst around people you don’t usually meet.
Restricting contact between people who do not usually meet to the extent it is practical
to do so.
Provide adequate ventilation.
Turn people with coronavirus symptoms away. We also advise additional requirements for businesses' COVID-19 risk assessments and advise that companies must:
Share the results of their COVID-19 risk assessment with their workforce.
Demonstrate to their workers and customers that they have properly assessed their risk and taken appropriate measures to mitigate this. You should do this by displaying a Staying COVID-19 Secure notification in a prominent place in your business and on your website.
4. KEY PRINCIPLES
The purpose of the COVID measures is to break transmission of the virus and reduce the risk of infection.
We should operate on the basis that we all have the potential to be asymptomatic carriers and should adhere to the safety principles to minimise risk by taking the following actions:
Restricting contact between people who do not usually meet to the extent it is practical to do so.
Wash your hands with soap and water, or hand sanitiser as often as possible.
Report any COVID-19 symptoms to your employer.
Coveryourfaceinenclosedspaces,especiallywheresocialdistancingmaybedifficultandwhereyou
come into contact with people you don’t normally meet.The purpose of the COVID measures is to break transmission of the virus and reduce the risk of infection.
5. GENERAL GUIDANCE & BEST PRACTICE
These are recommendations as to how to structure your live-action production and again, they will be constantly reviewed and updated. Productions should consider implementing the following:
A clear system for the communication and dissemination of COVID-19 related information, including:
> Signing of the Health Declaration Form in Appendix 1.
Ask all recipients to acknowledge receipt of COVID-19 briefings, maintain dialogue about COVID-19 safe practice and ensure that cast and crew are able to ask questions.
Set out clear procedures for instances of non-compliance with COVID-19 safe working:
> A concise process to implement immediately if any cast or crew member does not adhere to required COVID-19 safe practice; all cast and crew should be made aware of this before commencing work.
Every person who will be attending the location must sign the COVID-19 Health Declaration Form.
We have organised our best practices as follows:
5.1 HEALTH & SAFETY -GENERAL
5.2 BUDGET & CONTRACT
5.3 CASTING
5.4 THE SHOOT - GENERAL
5.5 WARDROBE
5.6 HAIR AND MAKE-UP
5.7 CREWING UP
5.8 HIRED EQUIPMENT
NB: These materials are for general information purposes only, are not intended to constitute legal or other professional advice and should not be relied on or treated as a substitute for specific advice relevant to particular circumstances.These are recommendations as to how to structure your live-action production, over and above Government guidelines and, again, they will be constantly reviewed and updated.
5.1 HEALTH AND SAFETY - GENERAL
Carry out a full risk assessment for each production at the recce. We recommend that this is done by a Health and Safety Officer.
All HoDs should submit their own departmental risk assessments which set out their COVID-19 precautions.
All crew and talent to provide contacts for family/household in case of emergency on the day of shooting, as per the Health Declaration Form.
You may choose to have a Health and Safety Officer on the shoot (e.g.: on a larger shoot with multiple elements) but their expertise and value usually lie in attending the recce, carrying out the risk assessment and making recommendations to minimise COVID-19 risks. We recommend you have a COVID Supervisor to implement and monitor COVID measures as per Appendix 2. This person must oversee the implementation and monitoring of necessary controls, with authority to stop unsafe working practices. They should have undertaken the APA COVID Guidelines Assessment Test.
Avoid sharing hand tools and personal property (mobile phones, pens, walkies etc.) Crew must be responsible for the safety and sanitisation of their own items.
In an emergency (e.g.: an accident, provision of first aid, fire, break-in, etc.) those involved in the provision of assistance to others should pay particular attention to sanitisation measures immediately afterwards including washing hands.
Conduct daily COVID-19 symptom checks with cast and crew. Consider the following:
> Ask each crew member daily whether they are experiencing COVID-19 symptoms
> Ensure that all symptom-checking data recorded complies with GDPR. Following detailed UK Government guidance.
If anyone suffers COVID-19 symptoms, they should inform the producer and follow UK Government guidance on self-isolation and testing which requires them to self- isolate and get a test. If the test is positive, then they are required to complete 5 days of self- isolation. They can then leave self isolation following 2 negative Covid tests taken 24 hours apart.
Anyone that does not have symptoms but has tested positive for COVID-19, is advised to stay at home and self-isolate from the day the test was taken.
5.2 BUDGET & CONTRACT
Cost the requirements of this protocol within your bids. Should regulations change, space needs to be made by agency/client to accommodate these if production incurs further costs.
State on your bid letter that anyone attending the shoot for the agency, client and/or production company will be required to adhere to the COVID-19 APA Shooting Guidelines.
The production should be planned to minimise COVID-19 related disruption risks so far asit is reasonably practicable to do so. In respect of the COVID-19 related risks to production which remain:
> Make provision for what happens in the event of such disruption (e.g., an agreement that the director or cast will be replaced if they become unavailable because of COVID-19).
NB: As per the Tripartite Agreement states the advertiser will underwrite costs incurred due to coronavirus for postponement or cancellation. The obligation of the production company (and agency) in that agreement is to plan the production in such a way as to minimise the risk of COVD-19 disruption and to mitigate the effects of such disruption if it occurs.
5.3 CASTING
Consider special precautions for any cast member who was previously classed as clinically vulnerable. See UK Government guidance on protecting the previously clinically vulnerable and definitions.
Ask agency to not confirm any cast until they have signed the Health Declaration form.
5.4 THE SHOOT - GENERAL
Consider reducing the number of people each person has contact with by using fixed teams, cohorts or partnering (so each person works with only a few others). For example,where social distancing may be impractical due to the degree of proximity required (such as intimate/fighting scenes, dancing, costume fitting, hair and make-up), fixed teams could be operated as follows:
> to group individuals into fixed teams that work together throughout a production or for specific periods of a production to minimise the risk of transmission beyond these fixed groups.
> to minimise transmission risk between fixed groups when they mix outside their group during shooting, during breaks or moving around a venue.
If necessary, have large enough areas for crew holding to enable alternating teams in the working area.
Consider increasing video monitors on set to avoid clusters of people.
Set out best practice personal hygiene for crew, in line with UK Government and Public Health Authorities’ guidance, including washing and thoroughly dry hands on arrival and during the day at regular intervals.
Provide clearly visible and spacious hygiene stations for washing, with plentiful supply of alcohol-based hand sanitiser and wipes and soap and water provided wherever possible.
All crew to be regularly briefed on and adhere to any safety guidelines or notices given on the day.
ConsiderconductingdailyCOVID-19symptomcheckswithcastandcrew.
Consider any space markers where possible and one-way routes to minimise interaction.
Providecoveredbinsforsafedisposaloftissues,coverings,gloves,etc.
Each department is responsible for keeping their own area and equipment clean.
5.5 WARDROBE
Complete costume fittings as much as possible during prep or off-site to avoid people congregating during production. If fittings have to be done in person, then the wardrobe department can set up clothes and supervise fitting from a safe distance. If fittings can be done at home, they should be and relayed via video-call or photos.
Consider using existing/talent-owned wardrobe if possible.
Talent dress themselves wherever possible.
Avoid sharing equipment, for example maintaining a dedicated sewing machine for one user.
5.6 HAIR AND MAKE-UP (HMU)
Limit the time spent in a hair and make-up chair whenever possible. Position HMU stations to allow appropriate social distancing or use Perspex screens between stations.
HMU department to utilise disposable kit where possible. Kit should remain unique to each artist.
Follow appropriate barbicide, sterilization and other disinfecting processes for all equipment after each application and immediate surfaces.
Ask performers to do own hair and make-up / touch-ups where appropriate. Request cast and supporting artists remove own make-up where possible.
If HMU crew need to break social distancing, limit face-to-face positioning where possible, remain within fixed teams (see The Shoot – General, above) and refer to the Face Coverings, Enhanced Protection and PPE section, below.
Keep HMU separate from Wardrobe. Provide sufficient space for both departments to maintain two metres distance.
5.7 CREWING-UP
It is advisable to hire a medic/nurse depending on the size of the unit.
Do not confirm crew until they have signed the Health Declaration Form.
For health and safety personnel see the Health and Safety – General section, above.
Require all crew to notify production if they develop symptoms prior to shoot.
Crew previously classed as clinically vulnerable, should be given special consideration and enhanced measures. See UK Government guidance on protecting theclinically vulnerable and definitions.
Notify all crew of specific production safety protocol requirements prior to the shoot (e.g., mandatory face coverings unless exempt, on-site testing.)
Provide crew with an email confirmation of their engagement for them to produce if the police question them on their travel to the location
NB: a waiver of rights by a crew member in respect of their contracting COVID-19 is of no value - English law does not permit excluding liability for causing injury or death through negligence, so a waiver is not part of this guidance.
5.8 HIRED EQUIPMENT - GENERAL
If equipment has to be shared, it must be regularly disinfected (including packing cases, handles, props, etc.) and always between users, following UK Government guidance.
All equipment hire facilities should have their own risk assessments and health and safety practices including their COVID-19 regimes and should provide you with copies.
Refer to the technician or company’s cleaning protocols and make sure they work for your production.
As equipment is usually expensive and specialised, please rely on crew or companies to clean before hire and after with instructions how to wipe down during hire period for sanitisation.
6. MENTAL HEALTH AND WELLBEING
It is important to remember that the covid-19 pandemic poses significant challenges to people’s mental health and wellbeing. Those having to work from home may experience social isolation while those having to come to a studio or location may be fearful of the risk of becoming infected.
Overall wellbeing and mental health will be considered within the risk assessment for production.
Producers and/or covid-19 risk managers responsible will understand the wellbeing needs and requirements of their teams or be able to direct individuals to support networks, and any communication will be treated in confidence and without prejudice.
Support will be offered and communicated clearly and regularly throughout the production process, which will range from a peer to peer communications through to appropriate helplines and/or online platforms.
Within the uk the film and tv charity is committed to supporting the film and tv workforce in returning to production after covid-19 and provides many useful resources for production along with support routes for the workforce, (here: https://filmtvcharity.org.uk/news-event/the-coronavirus-were-here-to-help-you-think-through-your-options).
7. FEEDBACK LOOP
It is vital that our production teams report any shortfalls (and successes/learnings) to ensure the risk assessment process is effective and actively reviewed.
Please contact the producer or the designated Covid-19 risk manager with any concerns, thoughts or suggestions.
We welcome and encourage feedback, and support people in raising concerns, which will be treated in confidence and without prejudice.
No one will be sanctioned for refusing to work in an unsafe environment.
8. COVID-19 HEALTH DECLARATION FORM FOR ALL ATTENDING OUR SHOOTS
APPENDIX 1 (click here for the online form)
COVID-19 HEALTH DECLARATION FORM FOR CREW / TALENT / AGENCY / CLIENT ATTENDING SHOOT
As part of our commitment to provide a safe working environment for all on set during the unprecedented, fast-changing COVID-19 situation, we need to ask you to confirm in writing, by signing below, that:
You have no cause to believe that you have COVID-19 (an NHS symptom checker can be found here).
You have not had a cough, or a temperature of 37.8 degrees centigrade or above in the last 14 days.
If you develop a cough or a temperature of 37.8 degrees centigrade or above at any point before or during or within 14 days following the shoot you will immediately inform the production company engaging you.
If you are over 70 years of age or have any pre-existing condition which would put yourself at increased risk of severe illness from COVID-19, as defined by the Government here, you must inform production.
If you are medically exempt from wearing a mask, you must notify production and disclose the reason for exemption upon returning this form and ahead of the shoot so production can make reasonable adjustments to ensure a safe working environment.
We may introduce testing as a further measure to mitigate risk on set. If so, you consent to a Covid test.
You will notify us immediately should anything change as regards to the above confirmations.
You have read, understood and agree to abide by the COVID-19 APA Shooting Guidelines.
For the purposes of GDPR you consent to our sharing and retaining your data to the extent that it is reasonably necessary for the safety of you and everybody on the production.
Please provide us with contact details of spouse / partner / home-dweller in the case of emergency on set, please provide those here.
Name of resident emergency contact: ............................................................................................................
Mobile of resident emergency contact: ............................................................................................................
Print your Name: ............................................................................................................
Signed: ............................................................................................................
Job Title:...........................................................................................................
Date of birth: ............................................................................................................
Your contact details if we need to contact you in event that crew or talent show symptoms of COVID-19 within 14 days of our shoot:
............................................................................................................
APPENDIX 2 -COVID SUPERVISOR ROLE
The COVID Supervisor should oversee and implement the recommended workplace requirements, as set out by UK Government, including hand and respiratory hygiene and depending on the level of mitigation on each individual set. These include assessing and applying social distancing requirements to the workingenvironment as per the production’s COVID risk assessment, ensuring accessibility and inclusivity in COVID-19 safer working practices and supporting and safeguarding those defined by UK Government as most at risk of contracting COVID-19. Examples of setting supervision and enforcement processes as below:
TASKS TO BE ALLOCATED TO A MEMBER OR MEMBERS OF THE PRODUCTION TEAM OR CREW OR, DEPENDING ON THE NATURE AND SCALE OF THE PRODUCTION, BY A COVID SUPERVISOR ENGAGED TO PERFORM THEM:
Make sure set is clean before shooting - oversee cleaners
Make sure the studio/location is well ventilated.
Make sure that hand-sanitizing stations are set up correctly
Make sure all areas have been set up correctly as needed - medic tent etc.
Ensure that all are aware of the source of appropriate face coverings and PPE and distribute accordingly
Make sure notices/posters are set up and visible
Make sure toilets are set up and clean
Coordinate temperature checking
Check communal areas are clean and not over-crowded
Note: this is a non-exhaustive list and production companies should add additional tasks they require depending on the circumstances of the production.
APPENDIX 3 -HELPING OUR PEOPLE STAY SAFE DURING THE COVID-19 PANDEMIC
The safety of our cast, crew and contributors isour highest priority. In order to ensure the health and safety of our people during the continued pandemic we have carefully assessed the risks of COVID-19 during production with reference to government and industry guidance.
In order to reduce those risks identified, as far as reasonably practicable, we will implement a package of control measures that will be in place during all stages of our productions.
How we are keeping people safe.
We are focusing on the following areas to ensure we can manage the risks of infection from COVID-19, carrying out specific assessments where necessary.
IN OUR OFFICES:
Minimising - minimising the number of people in our offices at any time.
Communicating - ensuring those who have symptoms or are ill know not to come into work and to return home immediately if they
become ill at work.
Commuting - considering the risks in commuting especially on public transport, introducing mitigations such as staggered start times.
Cleaning - increasing the frequency of cleaning.
Face covering - supporting our people in the safe wearing of face coverings on a commute and in scenarios where they choose to
wear.
DURING OUR PRODUCTION ACTIVITIES:
Travel - seeking to minimise travel requirements wherever possible.
Location - considering the physical capacity of space used as well as ensuring the provision of adequate hygiene facilities.
Work Activities - considering the activities that people are going to need to undertake across roles in a production and if these can be adapted or changed to reduce risk.
Work Equipment - managing the sharing of work equipment which is key to production from cameras and headsets to edit suites. Focusing on good hygiene and managing potential issues with touchpoints.
Work Patterns - reviewing work patterns to encourage fixed teams (cohorts) of people who don’t come into contact with other groups.
Catering and Rest Areas - reconfiguring catering provision and planning breaks to ensure our people are as safe as possible.
First Aid and Emergency services - planning activities to reduce the risk of requiring emergency services to be called as well as advice on COVID-19 risk.
Masks - as per the APA COVID Shooting and Office Guidelines.
Mental Health - the COVID-19 risk and the response has had a potential Mental Health impact for those working on productions which should be considered. Those having to work at home may feel isolated with those on set perhaps feeling fearful and anxious of the virus.
Monitoring - compliance will be monitored and if required people will be reminded ofthe COVID-19 working practices.