While C19CO might sound like the chemical formula for a carbon-based compound, it stands for COVID- 19 Compliance Officer and is very much a term that production and post professionals need to be aware of. It’s the newest addition to the roster of crew departments that make productions happen in the film industry in the Age of Coronavirus.
The C19CO is a stand-alone role that works within all stages of production to reduce the risk of coronavirus infection of cast and crew during film shoots. Becoming a C19CO is actually pretty straightforward. There are a few web-based companies that have developed a curriculum that typically includes classes held on a Zoom-type platform.
The class I took through healtheducationservices.net included an ex-EMT and an RN who essentially showed an educational slideshow that ended with a quiz on which you needed to make at least an 80% to be certified. Afterward, you’re sent a certificate and you can elect to have your name and contact information added to a database of other C19COs.
That’s just the beginning of the journey in every sense though. Let me share some insights about what that journey can look like for anyone working on set.
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Considerations should also be made regarding transportation to and from set with regards to the number of persons per vehicle. All persons designated as essential to a production should, at a minimum, have a documented negative COVID-19 test immediately prior to the start of production. As an added precaution, it may be prudent to require quarantine or isolate for 14 days leading up to the start of production. Testing should be either rapid testing or polymerase chain reaction (PCR) testing, with the latter being more accurate. Antibody testing, which may provide documentation of a past COVID-19 infection, should not be used as a metric for film productions. Some film productions may also require additional testing or more frequent testing depending on shoot duration. Once a cast or crew member has received a negative result from a test, out of an abundance of caution, they should self-isolate until they arrive on set.
At the start of a shoot day, the C19CO should be the first person on set and should be present until wrapping. Sanitizing stations, physical-distancing guidelines, and signage (proper handwashing, physical distancing guidelines, etc) should be implemented before general crew call. All individuals entering set should have been cleared prior to the shoot as essential (no unexpected crew or guests) and should have a documented negative COVID-19 test. Everyone entering set should also be screened; answering what is essentially a truncated medical history questionnaire that screens for symptoms and adherence to general state or local protocol for reducing COVID-19 transmission in addition to having their temperature taken with a contactless thermometer. Documented temperature should be less than 100 degrees. They should also remind every person of the importance of proper mask usage and handwashing technique as well as frequent hand sanitizing and physical distancing in a general safety meeting at the start of every shoot day.
During the shoot, the C19CO should – at all times – be aware of the persons present on set, in case contact tracing becomes necessary. In addition to general auditing of the set and personnel for adherence to the established safety protocols, they should also routinely clean high-touch surfaces such as door handles, railings, or light switches. Additionally, walkie talkies should be designated to one individual and not shared. Optimally, all sets should have adequate ventilation and could be open windows or doors, fans, or an HVAC system with adequate filtration. At the end of each shoot day, all equipment should be sanitized. If necessary, the C19CO should have a janitorial company perform a deep cleaning of the set, but I believe this will depend on the size of the shoot.
After wrapping the entire shoot, all screenings (I collected electronically through a service like DocuSign or Google Forms) should be sent to the producer within 24 hours of wrapping the shoot.
Because this is essentially protected health information (PHI), this information is subject to the health information portability and accountability act (HIPAA) and should not be shared or discussed openly. PHI should also never be included in the production wrap book. It is important to note that any development of symptoms or a positive testing result within 14 days of wrapping should be reported to the producer or other designated point of contact (could be C19CO) by the cast/crew member. It is then the production company’s responsibility to notify all personnel who may have been exposed and they should notify the local health department if more than 3 individuals receive a positive COVID-19 test as a result of work on the production.
Any individual exhibiting symptoms or a higher than 100-degree temperature with a contact-less thermometer during the shoot should be removed from set, production should be halted for a minimum of 24 hours, the set should be deep cleaned by a professional janitorial service, and all persons who may have had potential close contact should be notified. Positive and symptomatic personnel may return to set only if they have been asymptomatic for 3 days (in addition to the 10 days post onset of symptoms.)
Note: updated guidelines have reduced the asymptomatic requirement period to 24 hours. Use your own discretion.
If someone required hospitalization, they may return to set with a doctor’s note. Asymptomatic positive individuals may be allowed to return to set after isolating for a minimum of 10 days after receiving the positive test result. Individuals in close contact with positive personnel should self-isolate for 14 days, seeking medical advice if necessary if serious symptoms develop.
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For anyone who wants a better understanding of how to implement these processes and procedures, you can take one of these classes to become a C19CO. But there are a few things you should know before going into it.
First off, the class itself wasn’t overly in-depth and the quiz wasn’t overly complicated, which makes sense given how many possible scenarios and settings you have in production as well as the gamete of individuals who may become C19COs. Infection control was a significant component in the training, with emphasis on proper hand sanitizing and other such preventive measures.
As with most health-related occupations, learning the basics in a class setting is invariably different that application in the field. I did find the guidelines to be robust enough to mitigate the potential for outbreaks on an actual set and loose enough to apply to really any film set. I couch that by also stating that I feel one must be organizational, willing to adapt, able to lead and be direct, be an effective communicator, and I also feel strongly that prior healthcare experience is incredibly valuable.
The years-long training I received in the health-occupation classroom, the clinical training setting, and in various jobs gave me the ability to remain calm when we had an unexpected potential infectious individual on-set and the knowledge of pathophysiology that allowed me to really understand the likelihood of viral transmission to others on set in a given window of time since the individual’s potential infection. I also knew, based on that same information, that while this individual planned to have a rapid COVID-19 test performed the following day, that the result of that test would not be reliable to gauge HIS infection (because of a small theoretical viral load since his presumed infection time), but would be helpful in determining the risk to the rest of the cast and crew.
To clarify, I don’t necessarily believe this is information or skills that anyone operating as a C19CO NEEDS to have on set. But when faced with a director or a team who have devoted time, money, and effort to making a production happen, and you have a situation that may cause production to be shut down, bedside manner and the ability to allay fears based on that training is invaluable.
The position is not without its pitfalls, which are predominantly external to the actual C19CO. While film productions can implement safety protocols on set and have everyone test prior to coming to set, there will honestly never be a 100% safe and secure method of production, especially where production budgets are tight.
For example, a production could, in theory, mandate that all the cast and crew test then quarantine in a hotel for 2 weeks and then stay in this hotel for the duration of the production, where everyone would be isolated and monitored to prevent infection. Obviously this is an extreme method, but in a scenario where all those involved would be agreeable to such an arrangement, AND cost were not an issue, this would be an airtight method of preventing COVID-19 infection. In the real world though, this sort of thing typically isn’t an option. Many productions are on the smaller scale, both in terms of size and budget, so we are at the mercy of the honor system.
It’s also important to reiterate that the C19CO is a standalone department head with the authority to shut down production. This may come as a surprise to some production staff, and one may make the theoretical argument that this may cause some cast or crew to go ‘rogue’, in one way or another, by either choosing to operate without the use of a Compliance Officer or by ignoring the authority thereof. If the C19CO is in any way swayed from performing their duty either by threat or manipulation, this jeopardizes the importance and legitimacy of the role. The addition of the C19CO to the production team works best when there is a mutual understanding, respect, and adherence to a shared responsibility of maintaining a safe set. Everyone must be on board with this from the start of production planning.
Unfortunately, there isn’t a perfect solution to this unprecedented time of film productions during a global pandemic, and it’s important for those planning productions to understand that this is in no way a complete resolution of the risk of COVID-19, but risk mitigation. Aside from purely Draconian methods to ensure a totally safe production, the C19CO is a valuable asset to the production team as long as everyone understands that honesty (as with life) is the best policy.
To get a sense of how these lessons and insights were applied on a real production, read my Production During a Pandemic: Working as a COVID 19 Compliance Officer for a Film Production article.
Please note that the information contained in this article does not establish a standard of care, nor does it constitute legal advice. The information is for general informational purposes only and is written from a risk management perspective to aid in reducing professional liability exposure. Recommendations from the CDC are changing rapidly. You are encouraged to stay up to date with those details as specific liabilities and legal requirements may vary from state to state. ProVideo Coalition assumes no responsibility for the contributor’s statements of fact or opinion.