Ventilation, the 10-Hour Day, and No Day Players: 14 Takeaways from the PGA’s New COVID Safety Protocols
The Producers Guild of America (PGA) issued this week “COVID Safety Protocols for Producing Independent Productions,” a 57-page set of mandates, recommendations and guidelines for shooting during the coronavirus pandemic. Following similar documents — like the more studio-oriented “Safe Way Forward,” issued by IATSE, SAG-AFTRA and the DGA — the PGA paper, drafted by its Production Safety Task Force, both further codifies new industry safety practices while addressing issues specific to independent (i.e., non-studio or streamer-backed) productions. Additionally, like this summer’s documentary guidelines from Doc Society, Field of Vision and Sundance Institute, the PGA’s “COVID Safety Protocols” broadens its mandate to include the question: Should a specific production be shooting at all?
New COVID-19 production practices — zone systems, increased use of videoconferencing, physical distancing on set, scrupulous sanitation, PPE-wearing, etc. — have been much discussed in the industry press. So below in these 14 specific takeaways and items of interest I have focused on recommendations that seem especially relevant to independent filmmakers, worthy of discussion or which go beyond practices outlined in previous documents.
Ventilation. As mainstream reporting around coronavirus transmission has shifted from a concern over surface transmission, so too the PGA document. While cleaning and disinfecting sets and workspaces are still required, the larger hurdle for independent productions will be complying with requirements intended to reduce the risk of airborne transmission. “Every location, stage, shop, dressing rooms, offices, etc. must be assessed and upgraded or retrofitted for ventilation system compliance,” states the document. MERV 13 — a filter category used in hospitals, smoking lounges and high-end apartments — is the “standard baseline” for HVAC installation. Upgrades will need to be done to locations with HVAC filtration lower than MERV 12, and when HVAC systems are not used, portable HEPA units will need to be installed. Furthermore, as the paper notes, SAG is requiring producers submit detailed information about locations and their ventilation. Producers can expect to be asked to “detail size and location of each stage, set, location, office, shop, etc. along with information on outdoor access and existing circulation systems and how hourly ventilation and monitoring procedures will be used to reduce the spread of airborne particles.” The Health and Safety Supervisor, discussed below, will consult with engineers “and other experts” to evaluate the ventilation of all work spaces and will dictate the appropriate filtration systems.
Finally, recommended hourly ventilation procedures will cause work stoppages that producers and AD departments must now consider. “Work should shut down multiple times a day (every hour or two hours, depending upon size of space), team members should vacate the premises, and air systems turned on and doors and windows should be opened to move any lingering airborne particles out of enclosed spaces,” states the document.
10-Hour Shooting Day. The “Safe Way Forward” recommended 10-hour shooting days — as opposed to the U.S. industry’s 12 — and the PGA document furthers this recommendation. Such a limitation is so that “cast and crew immune systems stay strong and to allow time for monitoring, cleaning, and protocols that reduce transmission risk to be completed.” Of course, producers, ADs, PAs, drivers and others traditionally work even longer hours, and the document recommends that schedules be staggered so that no crew member works more than a 12-hour day. And within the shooting day the PGA recommends that crew be given “face mask/handwashing” breaks every one to two hours.
Health and Safety Supervisor/Department. With COVID-19 has come a whole new department. A cornerstone of all of the industry plans is a trained professional able to supervise and enforce COVID-safety procedures. This department is headed by the Health and Safety Supervisor (HSS), who reports directly to the producer. The Health and Safety Supervisor has some training in epidemiology while a second position, the Health and Safety Manager (HSM), is someone more schooled in production and who is able to implement safe practices on set. (If the HSM position is not filled, then productions should dedicate an additional production manager or coordinator to work solely with the HSS.) The PGA states that small productions should expect to increase the size of the Health and Safety Department by one person for every 20 cast and crew members. The PGA document also names a dozen additional crew positions that could be contained within the HSS department, including testing runners, medical checkpoint officers, and officers dedicated to the specific production zones.
“Red Light,” Shutdown Procedures, and Backup Crew. Shoots should have a plan in place to handle positive test results among crew and cast. The PGA document goes into detail here, describing “isolation rooms” which must be available on set to immediately isolate a UTM (“uncleared team member”), whose positive test result is returned during the work day. UTM’s must be given private transport home, be retested, and, in the case of a second positive, be quarantined for 14 days. Contract tracing procedures are detailed, along with a position-by-position breakdown of crew replacement procedures. In the case of a shutdown due to an outbreak, cast and crew should be prepared to quarantine for 14 days, and production should have plans to sanitize and secure offices and locations before recommencing (or returning to owners).
About replacement procedures, the PGA recommends productions have plans in writing to address the potentiality of sick essential personnel. If the director of a feature film gets sick, for example, it could be acknowledged that the shoot would shut down until they’re cleared to work again. Or, a pre-approved backup director could be hired. A producer should designate a backup to assume their responsibilities. Heads of departments should designate in writing their own replacements. A DP, for example, might agree that the operator could be bumped up, or an outside backup could be hired.
Insurance and Financier Assurances. The inability of independent productions to obtain production insurance covering COVID-related costs has led to a near-shutdown of independent productions. (The films that are now commencing or resuming production are mostly ones financed by studios or streamers who can self-insure — i.e., absorb the costs of coronavirus-related shutdowns and stoppages.) But there are some independents shooting — films whose financiers are assuming those risks and extra costs themselves. The PGA doc poses two questions to producers who are considering shooting. First, “If you do not have an insurance policy in place that covers COVID-19 related claims, do you have a government-backed insurance policy in place?” (Some countries do have government backing for film insurance at the moment.) Second, “If the above answer is no, is your financier willing to pay for any COVID-related insurance-type issues and claims, such as shut downs, crew pay, holding deals, start-up costs, etc (e.g. you or your financier can self insure)? And, if yes, is that commitment in writing?” If the answer to both these questions is no, the PGA recommends, “You should not consider production at this time.”
Liability Waivers. Making crew and even cast sign waivers absolving the production of responsibility in case of coronavirus transmission is something that’s still discussed by producers, but the PGA is firmly against this: “While it is common, especially in unscripted productions, to include liability waivers where the capturing of the content itself is inherently risky, these waivers SHOULD NOT also apply to potential exposure to and/or contracting of COVID-19 while on production. Exposure to, and contracting of, COVID-19 are not risks inherent to the capture of the creative content, therefore the PGA does not approve any form of a COVID-19 liability waiver.”
Mental Health. The PGA urges producers to be mindful of the mental health challenges of all of these new work rules and to offer support, if needed, to cast and crew in the form of mental health resources.
Creative Adjustments. If it’s not obvious by now, scripts shot during this pre-vaccine period will need to be adjusted creatively — if for no other reasons than to be able to absorb the additional shooting costs caused by PPE purchase, testing, the Health and Safety Supervisor/Department and more. But scenes will need to be adjusted to reduce their own inherent risk factors. For example, the PGA asks whether cast members in high-risk groups or those who feel unsafe can be shot separately. And whether scenes can be shot with ten or less cast members. Have the producers, director and writer thought about how to “re-direct the storyline in absence of a sick cast member?” And what about crowd scenes? Can they adhere to CDC distancing protocols and local civil authority rules? Can VFX be used to simulate crowds? Can stunt sequences be cut or shot in such a way as to eliminate physical contact between individuals? In the case of love scenes, will the production have an intimacy coordinator who can work in collaboration with the film’s Health and Safety Supervisor to insure the scene is shot safely?
Locations. The document recommends against any company moves within a day. (In other words, one location a day.) Furthermore, location moves should be done overnight so that the Health and Safety Department can sanitize and prep the space. Additionally, the document recommends that locations be
“secured, and COVID- Safety prepped and sanitized at least 24 hours in advance of start of shoot on that location.” (Consider the additional costs, then, of location rentals.)
Increased Budgets. Anecdotally I’ve heard producers estimate increased costs of anywhere from 6% to 30% of a budget due to compliance with COVID-19 procedures. The PGA recommends that these costs are contained within their own separate annotated line items and not be lazily budgeted as estimated “allows.” In addition to demonstrating that the production understands the scope and details of such safety compliance by breaking out all the individual line items, separating out these costs will allow producers to better negotiate with the guilds, such as IATSE and SAG-AFTRA, as higher budgets may push lower-budget productions into higher-budget tiers, increasing labor costs overall.
Testing. Rapid testing is the cornerstone of today’s production. The PGA asks producers if they have a relationship with a lab that can turn around a test in 24 hours as well as a backup lab for fast PCR test turnaround in case of a delay with the primary lab. (Some producers I know are securing mobile labs to process the volume of tests needed to test before and during production.)
The Safe Way Forward plan included charts showing the effectiveness of various frequencies of testing in stopping coronavirus spread on a set, with three times a week being the safe middle option (as opposed to once a week or daily). The PGA recommends Zone A members (cast and on-set crew) be tested three times a week and Zone B members (off-set, production offices, costume and set shops, etc.) be tested once a week. Anti-body tests are not accepted by SAG-AFTRA, and the union right now has only certified three testing kit providers: Helix® COVID-19, Bosch Vivalytic PCR, and Abbott’s ID Now RT-PCR Test. Producers who have shot recently have reported the cost of tests ranging anywhere from $89 – $150 per test. (Do the math! And consider the cost of testing personnel if tests are done on site.)
Crew Costs. Additional crew costs include payment for any required quarantine times, payment for pre-shoot testing, kit fees for anyone working at home, and recommended “COVID-19 bumps” for crew members tasked with assuming additional safety protocols or responsibilities. In addition, the need for crew members to receive a negative test result within 48 hours of working will impact production’s ability to fly in and out day-playing crew, such as additional grips and electrics, who might typically bounce from job to job. (“Avoid crew who ‘pick up extra work’ by doing night moves on other productions,” states the document. “Some crew are picking up three jobs in one 24-hour period! It’s hard to compete with the combined rates the crew can make, but we need our teams to adhere to strict social distancing and only work on our show, so consider making overall deals with typically day-player roles.”)
Cast and Scheduling Changes. Similarly, due to testing requirements, the PGA recommends that productions no longer drop/pickup an actor and that day players be turned into weekly hires. The document also recommends producers budget for a run-of-show pool of background extras.
Regarding the shooting schedule as a whole, the PGA document states for scripted work, “In order to have ample time to prepare and adhere to the 10-hour days, shooting schedules are recommended to be locked no later than fifteen (15) working days prior to the start of production.” For lower-budget, location-based independent films working with understaffed (and under budgeted) location departments, short preps, a multitude of actors, and where the schedule would usually hit goldenrod mid shoot, this will be a very difficult requirement.
Insurance. As stated above, insurance currently doesn’t cover coronavirus-related claims. But this will change at some point. But when it does, writes the PGA, “Insurance will get significantly more expensive. Add to that the exclusions of all communicative diseases and the possibility of being able to buy back those exclusions. There will be a significant increase in premiums.”
18 Months. Finally, these sobering words: “Producers are required to take steps to protect workers from COVID-19. Some experts predict that COVID-19 infection risks will persist for at least 18 months, and we cannot return to pre-COVID-19 production practices while the risks exist.”