“You’re gonna need a bigger boat”: COVID-19 reopening protocols require Hollywood to adopt significant changes to production

Hogan Lovells

Hogan Lovells

Hollywood got the greenlight to resume film and television productions from Los Angeles County Public Health officials last week. But art – like life – in a COVID-19 world could look very different under the detailed new safety regulations promulgated by public health officials. Crowd scenes, intimate scenes, and fight scenes are discouraged. Dialogue with no masks is permitted but should be brief. And actors are not supposed to touch their faces during filming.

Some of the protocols for film and television productions are similar to other businesses, including requirements for social distancing when possible, cloth face coverings, and frequent hand washing and sanitization. But many of the rules – perhaps reflecting the unique work environment – will require a major overhaul.

Productions, which have traditionally had workplace safety officers focused on things like construction safety, must now also have a workplace COVID-19 Compliance Officer (C19CO) to establish and enforce COVID safety protocols. The C19CO is supposed to be on-site or on-location “whenever possible when production work is being performed.”

Cast and crew will be required to submit not only to symptom checks but to regular, periodic COVID-19 testing, especially if they are involved in high-risk scenes (i.e., close contact scenes without face coverings for extended periods of time).

There will be other behind-the-scenes changes, too. Actors who can do their own hair and make-up, and/or handle their own wardrobes will be required to do so. Cast members will be asked to bring their own props (e.g., cell phones) or costumes when possible. The sharing of printed scripts is out, too. And the new regulations will largely eliminate the catering and craft services that kept crews fed and working through long days; buffets and communal food and drinks are prohibited.

Location shoots will have to be done in places large enough to permit social distancing, and rentals will need to be longer to permit sanitation before and after filming.

The county requirements, which affect all of the nation’s biggest film studios, might not be the only new protocols either. When Governor Newsom issued the statewide order permitting production to resume, he indicated that production companies would need to agree with unions regarding safety protocols. See State Guidance.

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Hogan Lovells

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