The Role of the COVID Compliance Officer

If we told you in 2020 that a pandemic-specific compliance officer would be the most critical positions on set you would have probably rolled your eyes. But with COVID continuing to disrupt productions, COVID Compliance Officers (CCOs) have become a key part to keeping productions safe.

In most cases, public health and union regulations require production companies to have a certified COVID Compliance Officer present on set from the very first scout days to tail-lights on the final day of shooting. But depending on what producer you talk to, the role of a CCO can have different meanings.

Some people think they’re licensed nurses, while others see them as glorified PAs. In this post, we’ll define exactly what a COVID Compliance Officer is and their responsibilities.

What is a COVID Compliance Officer?

A COVID Compliance Officer oversees coronavirus safety protocols on set. The job is loosely defined, usually requiring only the completion of a two-hour course. The title varies from COVID Manager or COVID Assistant to Health and Safety Coordinator.

A CCO is hired at the same time as other crew members. They sit in on pre-production meetings because COVID compliance touches every aspect of production – from locations, crew size and catering to how to set up the cameras.

Job responsibilities include administering COVID tests, sourcing safety equipment (called PPE or Personal Protective Equipment) and enforcing social distancing. On larger shoots, cast and crew are split into different zones (A, B and C), based on their contact with talent. The CCO is responsible for making sure these groups don’t mix. They have to intervene if crew members crowd together and don’t wear their masks properly. CCO’s are also required to maintain health and safety documentation and safeguard each crew member’s privacy.

Depending on where the production is shooting, the job can get even more complicated. Every shoot location has its challenges. Small sets or rooms are challenging for COVID compliance. Large studios are best as they provide plenty of room to social distance and normally have good air handling systems. But if a production is constantly moving locations, more planning is required to scout places with COVID protocols in mind.

Day in the Life of a CCO

Work often begins several days before a shoot begins. Check-in procedures are given to the producer to be included with the daily call sheet. These procedures include a medical history questionnaire for each crew member, screen for COVID symptoms and adhere to general state and local protocols.

Testing commences 72 hours prior to crew coming to set and everyone should have a documented negative COVID test result. Any crew with positive results will self-isolate and be scheduled for additional tests.

The night before filming, the CCO prepares PPE kits which will have masks and sanitizers at a minimum. They show up at least an hour before call time to ensure that sanitizing stations are set up, signage is posted (proper hand washing, physical distancing guidelines, etc) and check-in policies are in place.

All crew entering set are screened by the CCO during check-in. PPE kits are distributed and temperature is taken with a contactless thermometer. The CCO should also remind every person of the importance of proper mask usage and hand washing technique as well as frequent hand sanitizing and physical distancing in a general safety meeting at the start of every shoot day.

From there, they monitor every aspect of the production for proper safety, making sure everyone has their protective equipment on, sanitizing between scenes, and maintaining the proper occupancy for the square footage. After production wraps, CCOs stick around to disinfect and clean the set before going home to start prepping for the next day.

Set Medic vs. CCO

Health and safety positions are new to the entertainment industry as we have not had to respond to such a destructive pandemic since the 1918 Influenza Pandemic. A few organizations were prepared to respond such as National Set Medics and IATSE Local 80.

However, the job of a Set Medic and COVID Compliance Officer are very different, though both must have a medical understanding of the coronavirus. They work together to provide the strongest scope of safety on set.

CCOs understand the health and safety protocols in their particular county and state, as well as the requirements of various unions (SAG/AFTRA, DGA, IATSE). They stay updated on guidance from the Center for Disease Control (CDC) regarding transmission and how it affects protocols. The job of a Set Medic is to respond to emergencies and triage on site. A medic is not allowed to take on a secondary responsibility on set.

Why? Medical negligence. A medic cannot be engaged in a secondary activity when they are acting in the capacity of a medic. A CCO can have a second responsibility as long as it’s not that of a medic.

Challenges

The position has many challenges. Some productions ignore the authority of the CCO altogether. A safe set works best when there is respect for the CCO position and adherence to health and safety protocols within the entire production team.

Even when productions implement safety protocols on set, a 100% safe and secure production is not guaranteed. When there are concerns about safety, the COVID Compliance Officer has the power to discipline, or even fire, health and safety protocol violators. In worst case scenarios, they can even stop a production. Given that shutdowns on large productions can cost hundreds of thousands of dollars a day, that’s a huge responsibility.

No matter the size of the production, nothing is more important than protecting your cast and crew. Productions can’t cut corners or break rules that endanger cast and crew. Prevention in a time of a pandemic is expensive but positions like a COVID Compliance Officer are the best strategy to keeping your set safe.

Health and Safety Protocols during the Coronavirus Pandemic

For film and video production companies, the coronavirus pandemic (COVID-19) offers a lesson in the contagion risks facing workplaces that need close proximity and interaction to function. Social distancing is almost impossible when offloading equipment, setting up camera and sound gear, applying hair and make-up, or getting into a 12-passenger van to get to the next location. And careless sanitary conditions on set have long been one of the production industry’s dirtiest secrets.

The sad state of hygiene on set has largely been accepted as part of the job. But when productions started shutting down nationwide to slow the virus’ spread, a debate emerged on what a safe (and sanitary) set looked like. Until now, having hospital information on a call sheet and a Set Medic on bigger productions was often the only health and safety protocols in place. That’s not nearly enough.

At some point, production will ramp up again and when it does, COVID-19 protocols need to be put in place. Although extra preparation is required, establishing a hygienic working environment is both possible and easy to implement. Here are some basic protocols to follow.

Common Sense Hygiene

Although there’s lots of information circulating about the virus, it’s best to follow what the health authorities are reporting. The CDC and numerous state authorities have issued recommendations to help prevent the spread of any respiratory disease. The nature of the production industry suggests additional guidelines, including:

  • Determine is anyone can effectively work from home during prep, shoot or wrap.

  • Keep workspaces clean. Disinfect them daily. The CDC recommends using diluted household bleach solutions or alcohol solutions with at least 70% alcohol.

  • Limit specific areas of the set to essential crew and personnel.

  • Require frequent and thorough hand washing by all crew, without exception.

  • Maintain social distancing of no less than 6 feet whenever possible on set. Have crew wear masks when that’s not possible.

  • Respect 12-hour turn arounds for all departments so people can get enough sleep.

The Los Angeles County Department of Public Health has an excellent fact sheet on coronavirus that’s clear and concise. Attach it to call sheets and post on set.

On Set

Once on set, COVID-19 should be one of the first things talked about at your Safety Briefing. Stick to the facts, don’t offer opinion or spread rumors. Distribute a Health and Safety Protocol sheet to crew and place signs around the set explaining not to shake hands and to let the Producer know if you are feeling ill. Some commonsense measures include:

  • Have payroll, waivers and talent/location releases all done electronically with no paperwork exchanging hands on set.

  • Limit specific areas of the set to essential crew and personnel. Create policy of no Visitors on set.

  • Allow one department at a time to “step in, step out” of a set up, before the next department.

  • Provide masks, gloves, sanitizing wipes, tissues, and hand sanitizer in production spaces.

  • Place signage around restrooms and food services to wash hands and be clean.

  • Self-monitor for symptoms of COVID-19 and report to your department head if you are sick or experiencing signs. Stay home when you are sick.

Set Medic

The Set Medic is often the medical provider hired on larger productions and works as the first aid department head. They are an excellent resource to research protocols for safe filming and can also help in creating a Health and Safety protocol sheet for the production. Every state is a little different, but there are health and safety bulletins used throughout the industry.

Schedule a time at the Preproduction Meeting (or sooner) to have your Set Medic fully explain all health and safety protocols to cast and crew.  Then empower them, and the Assistant Director, to enforce all rules (firmly but gently) on shoot days.

Wardrobe, Make Up and Hair

Taking certain precautions when applying makeup can keep everyone involved safe. Disinfect and sanitize any tools (tweezers, scissors, brushes, etc.) or products to make sure they are hygienic. Other tips:

  • Keep the number of people in makeup room/area to a bare minimum.

  • Work stations need to be cleaned between each user and distanced a minimum of 6 feet apart. Make-up chair and its handles should also be sanitized.

  • Before and after hair and make-up session, both talent and make-up artist are required to wash or sanitize their hands.

  • Applicators are not permitted to be reused on different people. This includes mascara and lipstick.

  • Ensure only wardrobe department touches clothing until it’s decided what the actor will actually try on.

  • Disinfect jewelry, glasses and accessories with sanitizer that will not cause damage.

  • All background extras, should wear their own clothes and dress from home. If that’s not possible, production should provide dressing facilities that allow for social distancing measures.

Craft Services and Catering

The area where your crew congregates also needs special attention. Get everyone to wash and sanitize their hands prior to eating any meal. As with production spaces, wipe everything down any time someone not on the crew touches it. Use paper towels to clean surfaces instead of repeat-use towels. Other to-dos include:

  • Buffets are not permitted. Meals and drinks must be served as single serving portions. Individually boxed meals are ideal but realize some may prefer to bring their own food.

  • Stagger meal times to decrease number of people getting food and seating simultaneously. Have food served to crew, as opposed to allowing self-serve.

  • Sanitize your hands before touching craft service equipment, including inside ice chests, the handles of serving utensils or other commonly shared surface.

  • Use suitable utensils, spatulas, tongs, deli paper, dispensing equipment, or gloves for food.

  • Communal ready-to-eat foods (chips, nuts, candy, cookies, etc.) are not permitted. Remove any bowls or canisters of snacks that crew could reach into. Provide snacks in individual, prepackaged portions or put them in plastic bags or Dixie cups for people to take away.

  • Reduce and streamline the variety of beverages. Offer the capability to refill an individual’s reusable water bottle without contact between refill source and bottle.

Fighting COVID-19 on set cannot be taken lightly. It requires a paradigm shift. Although the specifics will depend heavily on the type of production, new procedures and protocols rooted in safeguarding health need to be adopted. By creating cleanliness standards, we can reduce the risk of exposure on set.

If you’d like a copy of the in-depth Health and Safety Protocol sheet we distribute to our crews, please email us at info@moviemogul.tv