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HomeColumnsGuest Editorial: Inoculating Your Film From COVID in Seven Steps

Guest Editorial: Inoculating Your Film From COVID in Seven Steps


Intro by Edward Douglas:

We’ve been covering the return to production quite heartily here at Below the Line, and every once in a while something hits my inbox that seems perfectly attuned to what is on all of our minds, and that is how everyone can return to work safely with COVID-19 not seemingly going away any time soon. With that in mind, we’re sharing this piece from entertainment attorney Harris Tulchin, whose full bio you can read at the bottom of this article. Harris Tulchin & Associates/ Tulchin Entertainment is an international entertainment law firm, media production company, social influencer consulting firm and Harris Tulchin is the Co-Author of the Independent Film Producer’s Survival Guide.


Written by: Harris Tulchin, Kyle Moser, Pamela Bille

Harris Tulchin
Harris Tulchin

Recently, a modest-budget movie production shooting in New Mexico was temporarily shut down for four days as a result of COVID-19.  The producers thought they were doing everything right, testing on a regular basis and even performing extra rapid antigen tests on cast and crew that all came back negative, but due to a delay in the lab reporting to SAG-AFTRA, the Guild had no choice but to shut down the production.  Until this shutdown, there was no COVID-19 outbreak on set or even a positive test result, but because the production did not strictly adhere to the Guild-mandated protocols, it was shut down, losing precious time and incurring significant additional costs.

More specifically, a series of unanticipated events led to the shutdown, but they could have been prevented had the producers been prepared.  First, the contractors supplying testing materials to the production lacked sufficient testing materials, which led to some personnel not being tested on the specific day required by the Guild protocols. Second, the Veteran’s Day holiday fell on a Wednesday, and the lab was closed, which resulted in some crew members’ test results not being confirmed by the lab on time. SAG requires that 100% of personnel in Zone A (more on that below) test negative, and the production’s testing lab could not provide the test results for Zones A and B quick enough to avoid a shutdown under the SAG rules. In other words, the lack of testing and timely lab results shut down production and not COVID-19 itself. This article is not a referendum on the Guild or its practices but rather a guide to filmmakers on steps to take to navigate productions through these uncertain times and help prevent an unexpected shutdown and significant loss of time and money.

COVID-19 has been a topic of conversation in just about every phone call, e-mail, and Zoom meeting for the better part of nine months now in the film industry. We started out in a lockdown, then figured out that there are ways to live with COVID-19, at least in some areas around the world. But one thing is clear: COVID-19 is not going anywhere anytime soon, and in order for the film industry to stay afloat during this time, productions must be adequately prepared with an action plan well before principal photography begins. It is important to understand that merely following guidelines will not be enough to prevent COVID-19 from halting film productions. In order to have the best chance of completing films on-time and on-budget, productions will likely need to go above and beyond the local, state, and union health and safety guidelines.

Considering states are beginning to shut down again, with stay-at-home orders, restaurants only offering takeout, and curfews starting to take effect, despite promising news releases about effective vaccines, productions need to realize that COVID-19 is not going away soon, and it is even more important than ever to be vigilant. By following the seven steps listed below, productions will have a better chance at a successful, safe, and on-budget startup and completion of production.


The Zone System, from the “Safe Way Forward” safety guidelines by the DGA, SAG-AFTRA, IATSE, and Teamsters, is the essential foundation which every production company must implement before even thinking about launching a film production. The “Safe Way Forward” guidelines set out 3 zones: Zone A, Zone B, and Zone C.

Zone A is any space where physical distancing and mask-wearing is strictly enforced. This area could be described as the physical set where performers are working alongside the crew. Specifically, this zone covers actors/actresses engaged in close or intimate contact or intense physical exertion, along with any crew who is involved in these scenes.

Zone B covers areas around production that is not Zone A. For example, the unions and guilds say Zone B could be “a production office, base camp, a vehicle, a control room/truck, basically any workspace or place that a crew member may be performing work.”[2] Zone B will most likely be a blanket around a Zone A or multiple Zone A’s. Zone C is anywhere outside of the production where people may reside or visit when not working. People working in Zone B are unable to move into Zone A unless they have been tested and cleared 24 hours before entering Zone A.

Regular testing of the cast and crew should be used to mitigate the risk of infection and spread of COVID-19. Cast and crew need to understand that frequent testing is necessary whenever they are in Zone A. The most effective method, if possible and economically feasible, would be to test all Zone A and Zone B people at intervals more frequently than what the unions and guilds require. While SAG requires testing only every 3 days, testing everyone in Zone A on a daily basis may be more cost effective, given that daily testing likely costs substantially less than shutting down production.  Ideally, production teams should consider, when budgeting, having Zone A personnel tested daily (either by lab testing or rapid testing on site) while Zone B personnel should be tested at least 3 times a week. In short, production teams should be aware that a lack of adherence to the Zone System and its testing protocols could have dire consequences to any production, that could arise without warning, whether by an abrupt shutdown due to testing problems or an actual COVID-19 outbreak on set.

If you have more testing, more frequent mask-wearing, more hand washing stations and sanitizer, and more social distancing, then there is a better chance of avoiding problems during production. If personnel do not strictly adhere to the safety protocols, then the risk of COVID-19 infiltrating the production will increase exponentially.


The scientific research shows rather convincingly that the most effective method to stave off COVID-19 is for everyone to wear a mask at all times on location. Trying to find an easier, or less expensive, option to shutting down production simply is not available yet.  In fact, productions need to strictly enforce the rule that cast and crew wear masks whenever they leave their lodging or else the other safety protocols will be rendered useless. In addition to policing mask-wearing at all times (even for people who are not in close proximity to others), productions need to have an extra stash of disposable facemasks accessible for the cast and crew whenever needed. Disposable masks should be replaced each day. Reusable masks should be cleaned every day and discouraged in favor of disposable ones for increased cleanliness.  Crew in high density areas should be prepared to wear face shields as well as disposable face masks, when appropriate, depending on the work they are doing. Just as hospital workers in the ER and ICU wear face shields with face masks, production teams should consider wearing face shields as an additional inexpensive and easy safety measure to further reduce the risk of shutting down your production. The production and each individual working on the production’s personal commitment to following even more than the guidelines require should result in a safe and on-time and on-budget film.


As stated previously, local, state, and union guidelines should be considered the bare minimum and not the gold standard. Many times, the union and guild guidelines are much stricter than the local and state protocols and understanding that there are multiple governing guidelines to follow is important for every producer who is trying to get their production up and running and not shut down.

Think about the minimum protocols from these authorities similarly to the NCAA safety protocols in place. Have the NCAA guidelines prevented COVID-19 from affecting college sports? Not one bit. In a recent week of college football, almost 25% of the scheduled games were canceled, and that rate is trending upward. The lesson to be learned here is that productions cannot scrape by only following the minimum procedures. COVID-19 is so infectious that even following these minimum guidelines perfectly will not ensure that the film will be completed on-time and on-budget. Productions should aim to go one or more steps beyond all required procedures to decrease the chances that COVID-19, or simply insufficient timely testing and lab results, will be the cause for a shutdown. Productions should increase the number of hand-washing stations, keep the environment controlled with security who track all movement to and from the location (for increased contact tracing effectiveness), and strictly police mask-wearing. Do not assume that one successful production day ensures the next day will be safe.  The rate of COVID-19 infection continues to rise, which means that productions need to stay vigilant in fighting a stronger spread.

Producers and executives should be familiar with the locality’s positivity rate where the filming will take place and plan that after their cast and crew have been tested, there is a fairly good chance that their positivity rate will match that of the locality. The NFL has tackled the issue of what happens when key players or coaches test positive and are unable to travel with the team for that week’s game. The NFL increased roster spots on the practice squad to accommodate teams losing players in a given week. Similarly, productions need to have their own “practice squad” if cast and crew are unable to continue because of positive tests or contact tracing. If you have to replace crew members, make sure to have several alternatives for key positions on backup call and speed-dial. Additionally, producers and executives should regularly meet and communicate with (if not become friendly with) the union and guild COVID-19 safety and compliance officers and local COVID-19 officials to open a line of communication and show a complete willingness to work with them as they could be the difference between starting work on a given day or shutting down. Indeed, many of the decisions these officials make can be totally subjective, but if you are in regular contact with these officials, the likelihood of a random shutdown will significantly decrease. Every production company should also appoint an executive who oversees COVID-19 compliance while on location and who develops regular dialogue and a relationship with government and guild COVID-19 compliance officials. Educating executives about the increased COVID-19 safety protocols is only half the battle; the cast and crew also need to be trained and informed about the increased safety measures on the production before they travel to the location or start on the job.


All cast/crew should be familiar with the procedures that will be in place on location. The Safety Guidelines for the Film and Television Industry in Ontario lays out a list of tasks that productions should implement and share among the cast and crew in order for everyone to be on the same page with regards to safety guidelines and protocols during filming:

  • Provide workers with phone numbers/contact information of the people they should contact regarding COVID-19 response.
  • Consider additional support staff such as set medics, external cleaning crews, etc., to put safety protocols into action.
  • Consider requiring sign-off (e.g. digital sign-off) that people have received and reviewed this guidance and any producer policies and protocols.
  • Consider digitizing paper-based procedures like expense submissions, purchase orders, call-sheet and script distribution, etc.[4]

Not only do the cast/crew need to know this information for their own safety, they should not feel unprepared or shocked by the stringent rules and enforcement when they arrive. All employees should be trained on how to properly perform the daily cleaning and disinfecting protocols, hygiene, and respiratory etiquette. Nobody should feel uneasy or stressed about others not following the guidelines. One or more independent COVID-19 Compliance Officer(s) with specialized training, responsibility, and authority for COVID-19 safety compliance and enforcement will need to be in the workplace to address issues as they arise and to strictly enforce the protocols from the local, state, and union guidelines.[5]


It is imperative to have more than enough guild and governmental approved testing materials to test all the personnel. You do not want to face a situation where your lab or COVID-19 supply contractors do not furnish enough supplies for the number of personnel who need to be tested and for the lack of complete testing to be a reason someone has to quarantine or prevent filming from continuing. Constant contact with those in charge of COVID-19 issues at the guilds and local and state agencies in case any issues arise during production is critical to the success of the production. The production company must also stay in contact with the personnel at the lab who can make sure the production’s tests can be prioritized in case there are any issues that come up unexpectedly that pertain to the supplying of test materials or the reporting of the test results to the proper authorities.

Rapid testing is starting to become commercially available to the public and securing the supplies and lab to conduct these tests could be a major breakthrough in the struggle against COVID-19. Some guilds do not yet approve available rapid testing, but producers should have rapid testing materials available and continually seek to find new tests that can be rapidly processed that could be approved or approvable by local guild / local governments in case a problem arises with a lab.

In addition, know where the lab is and how the lab operates. Producers must take into consideration holidays and weekends for weekly start dates. Some productions start the week on Thursday, not Monday, and if a lab is closed on weekends (or for a mid-week holiday), then the delay in reporting test results could cause the production to be temporarily shut down, so plan ahead for reporting and testing purposes. Make sure you have an arrangement with several approved labs if there is a mid-week holiday or weekend that disrupts regular testing and reporting. As explained above, the main issue with our New Mexico production was that the workweek started on a Thursday, making Wednesday the deadline for reporting to SAG. Unfortunately, the lab was closed due to it being a national holiday, and the production was shut down by SAG when it started its new production week on the Thursday after the holiday and all the necessary test results were not in.

It is important that productions think and plan ahead as COVID-19 has brought with it so many new complications that have never even been thought about before. Solutions for this kind of problem, and others, is one that a production might not think of before it is too late to correct. It is imperative that productions starting up again understand that there are issues that go beyond positive tests that need to be prioritized.


Adhering to proper hygiene, cleaning, and disinfecting protocols from the Center for Disease Control are another key in preventing COVID-19 from halting productions of films. Productions need to have, at all times, numerous hand washing stations with soap and water throughout the location and should strictly require (not just encourage and promote) cast and crew to perform disinfectant wipe-downs of all high-touch areas and equipment, including food areas. Wipe-downs should be performed as often as possible, and mandatory upon arriving at the location, after using the restroom, before and after eating or drinking, after handling shared equipment, for at least 30 seconds of duration.[6] Productions should also be prepared to have heightened cleaning and disinfection practices using only EPA-registered disinfecting methods and supplies recommended by public health authorities.[7]

In addition, prior to the start of production, there needs to be adequate training or hiring of cleaning professionals so as to effectively and efficiently prevent the spread of COVID-19 on surfaces. The Safety Guidelines for the Film and Television Industry in Ontario lays out strict and well-thought out cleaning and disinfecting guidelines that new productions should follow.[8] Such policies and protocols include:

  • a schedule to regularly disinfect high-touch surfaces/objects (e.g. equipment, props, tools, keyboards, telephones and handsets, desks, light switches, door handles, washrooms, handwash stations, etc.)
  • identifying which disinfectants are appropriate for specific surfaces/objects/equipment. This may include UV disinfection for certain electronics that may be damaged by liquid disinfectants.
  • ensuring that appropriate individuals are adequately trained on the use of the specific disinfectants. This should include being familiar with public health guidance about cleaning and disinfection to combat COVID-19 in particular.
  • assignments of specific cleaning tasks to certain people (whether general/production wide, or department-specific) and ensuring that these individuals have/receive appropriate training.
  • instructions to use disposable cloths or paper towels, whenever possible.
  • instructions that reusable cloths, sponges, mops, etc., should be disinfected or washed after each use and rotated and disposed of as needed.
  • protocols for the safe disposal of Personal Protective Equipment (PPE).
  • protocols for the safe disposal of cleaning/disinfecting materials.[9]


Quarantine measures should follow the CDC recommendation of 14 days of quarantine. Productions should ensure that people in quarantine have no access to common areas, use room service only, and have outdoor access only if supervised and controlled. Finding a suitable location to quarantine is also important as security needs to be able to safely monitor the quarantined people to make sure no quarantine is broken. Everyone arrives to a production set at different times, so strict quarantine protocols need to be followed or else the whole production can quickly fall victim to COVID-19.


In Georgia, Tyler Perry outlined a plan to safely start up production for the TV shows Sistas and The Oval. He called this plan: “Camp Quarantine.” Similar to the NBA’s bubble for the postseason, Camp Quarantine followed strict COVID-19 protocols that went beyond the safety requirements of Georgia and the union and guild protocols. Before the cast and crew were allowed into Camp Quarantine, they had to undergo testing 16 days before traveling to his studio in Georgia. Every person who interacted with the cast was required to wear a mask at all times. The cast and crew had their own individual rooms where they had to quarantine for two weeks upon arrival to ensure that nobody would shed the virus even if they tested negative from the initial tests. Perry mitigated the difficulties in creating a bubble by providing food trucks, movie nights and an open bar for the cast and crew during production as nobody was allowed to leave the bubble unless they were finished with their jobs for the production. Even though some personnel tested positive initially, the second season of Sistas was finished ahead of schedule, and the entirety of the cast and crew, while inside Camp Quarantine, tested negative for COVID-19. Perry’s Camp Quarantine concept recognizes the dangers COVID-19 brings to the cast and crew of a production which led to them pioneering an extensive plan to safely and efficiently restart film production that focused on stricter protocols than what was required of them. Obviously, there are cost-benefit issues to be considered with such a process, but in most cases, the costs associated with COVID-19 prevention and protocol compliance pale in comparison to the costs of a shutdown.


Returning to the story of our client’s production, after working with the Guild, we were able to arrange with the Guild and the producers for a hiatus and relocate part of the production and vendors to a facility in Los Angeles that was capable of providing the necessary protocols. Had the production followed these steps BEFORE it commenced principal photography, it could have avoided the delays and unnecessary costs involved in the shutdown and moving the production.

COVID-19 has changed all of our lives, but we have adjusted and have learned ways to live with it. Production companies should not be scared off, but rather, enthusiastically embrace the safety protocols that can guide them through the challenges of COVID-19. The most successful way forward for productions is to follow the local, state, union and guild safety procedures, while also going a step further and following the policies and practices outlined above. If everybody is focused on the common goal of keeping production alive during COVID-19 and dedicated to their individual responsibilities, then we can keep our motion picture production on-time and on-budget without unnecessary delays.

Hopefully, your take-away from this article is a better understanding of how to implement the most effective COVID-19-prevention protocols because abiding by even the most vigilant practices is far less expensive than an outbreak, or simply a testing mistake, shutting down production for even one day.

©2020 Harris Tulchin & Associates, Ltd.

HARRIS E. TULCHIN is an entertainment lawyer, producer, author, and producer’s representative. He graduated from Cornell University and Hastings Law School, and has practiced entertainment, communications, and multimedia law since 1978. He has served as Senior Vice President of Business Affairs and General Counsel for Cinema Group; General Counsel and Head of Business Affairs for KCET Television; Senior Counsel for United Artists; Director of Business Affairs at MGM Television; Counsel for American International Pictures; Counsel for Filmways Pictures; and Counsel for Orion Pictures. Mr. Tulchin is the co-author of a book considered one of the bibles of the motion picture industry, entitled: The Independent Film Producer’s Survival Guide: A Legal and Business Sourcebook, published by Schirmer Press, New York (2002, 2005, 2010).

As Tulchin Entertainment’s president / owner, Harris E. Tulchin has produced or executive produced more than 20 films including To Sleep With Anger starring Danny Glover and directed by Charles Burnett (Sundance, Cannes 1990, winner of four Independent Spirit Awards); Guy directed by Michael Lindsay-Hogg, starring Vincent D’Onofrio and Hope Davis (UK / Germany, Venice 1997); The Lightkeepers starring Richard Dreyfuss and Blythe Danner; The Golden Boys starring Bruce Dern, Rip Torn, David Carradine, and Mariel Hemingway; The Devil’s Double, directed by Lee Tamahori (Once Were Warriors and Die Another Day) with Dominic Cooper and Ludivine Sagnier, it was an official selection of the Sundance, Berlin, Los Angeles, and St. Petersburg, Russia (where it won Best Gala Premier) Film Festivals. (Belgium / the Netherlands / Malta, Berlinale Panorama 2011); The Comeback Trail (Executive Producer) written and directed by George Gallo (Midnight Run, Bad Boys, Middle Men) starring Robert De Niro, Tommy Lee Jones, and Morgan Freeman; and Home (Executive Producer), a Germany co-production directed by Franka Potente starring Kathy Bates, Jake McLaughlin, Lil Rel Howery, and Stephen Root. He also served as Senior Executive Business Affairs and Legal Consultant on The Third Person, a Belgian/Italian coproduction with Corsan, NV and Cinecitta Studios written and directed by Paul Haggis (Crashand In the Valley of Elah), starring Liam Neeson, Mila Kunis, James Franco,  Olivia Wilde, Adrien Brody, Maria Bello, and Kim Basinger (2012/2013); Killing Season starring Robert De Niro and John Travolta (Georgia / Bulgaria, Corsan / Nu Image Co-production 2012); Singularitydirected by Roland Joffe and starring Josh Hartnett and Tamsin Egerton (Australia / UK / India, Corsan 2012).

Tulchin’s current projects include: Leo From Toledo starring Mel Gibson; The Lowe Men (Executive Producer), a British comedy about identical twins, one a bank robber and one a policeman; Framed (Executive Producer), based on the acclaimed book of the same title by Tod Volpe based on Tod Volpe’s journey from art dealer to the stars, to his incarceration for tax fraud and his ultimate repentance; StarStruck (Executive Producer), a five-part mini-series written by Andrew Chiaramonte based on the life of the genius and convicted heretic and father of the scientific revolution, Galileo Galilei; DieRy (Executive Producer), which is currently in post-production; American Terrorist (Executive Producer), a psychological thriller that recently premiered at the Hollywood Film Festival; The Second Sun (Producer’s Representative), a period drama that also recently premiered at the Hollywood Film Festival; and Belle de Jour (Executive Producer), inspired by Luis Buñuel’s classic 1968 film of the same name.

He has lectured extensively at forums such as UCLA, USC, AFI, IFP, ShowBiz Expo, IFTA, The Sundance Producer’s Conference, Singapore Film & Television Conference, Cannes, the Los Angeles Independent, Cine Asia (Bangkok, Thailand and Beijing, China), Galway (Ireland), Los Angeles / AFI and Santa Barbara Film Festivals, Digital Hollywood, The Learning Annex, The International Film School in Cuba, Variety’s New York Film Finance Forum, and numerous others. Mr. Tulchin has been a member of the Full Sail Entertainment Business Academy Board of Advisors (Orlando, Florida) and was an Adjunct Professor of Entertainment Law at the Entertainment Law Institute of Southwestern University Law School.

A founding member of the Orange County Flyers Professional Baseball Team’s management team, Harris has been involved with all aspects of the Flyers’ legal and business affairs including the acquisition of the Flyers team, assets, and territorial rights from the Golden Baseball League, the Golden Baseball League operating rights agreement, stadium lease negotiations and new stadium committee, all major business transactions, managers and coaches contracts, players contracts, league rules and regulations, player trades and options, media, broadcast, and licensing arrangements, and all other key Orange Flyers Baseball deals.

As a producer’s representative, Mr. Tulchin has sold and licensed hundreds of films on behalf of his production company clients.  Mr. Tulchin was also an IFTA arbitrator, has served as an expert witness in numerous cases involving the motion picture and television business.

Mr. Tulchin negotiated a five picture deal with Corsan and Emmett/Furla Films for US $125 million, which contained two Martin Scorsese Pictures and a Picture starring Bruce Willis.  He has represented Bavaria Film in Germany and Origo Film Group in Hungry, as well as Corsan, NV, the Belgian Film Finance and Tax Fund.

Mr. Tulchin is on the board of advisors for the Hollywood Film Festival.  He is also on the Board of Advisors of, and the chief legal and business advisor to, Cinezen Blockchained Entertainment, the new blockchain/cryptocurrency video on demand distribution platform based in Sweden and a Board Member and Senior Executive VP of Business Development of The Clubhouse, an owner and operator of multiple social influencer content houses or mini-studios.

[1] 2020. THE SAFE WAY FORWARD. Available at: <> [Accessed 19 November 2020].

[2] 2020. THE SAFE WAY FORWARD. Available at: <> [Accessed 19 That experience served as an example of how quickly a production can come to halt due to insufficient testing. November 2020].

[3] 2020. New Mexico’S Film + Television Production Health Safety Initiative. New Mexico Film Office. Available at: <> [Accessed 20 November 2020].

[4] 2020. Safety Guidelines For The Film And Television Industry In Ontario. Film and television industry health and safety during COVID-19. [online] Ministry of Labour, Training and Skills Development of Ontario. Available at: <> [Accessed 20 November 2020].

[5] 2020. Safety Guidelines For The Film And Television Industry In Ontario. Film and television industry health and safety during COVID-19. [online] Ministry of Labour, Training and Skills Development of Ontario. Available at: <> [Accessed 20 November 2020].

[6] 2020. Proposed Health And Safety Guidelines For Motion Picture, Television, And Streaming Productions During The COVID-19 Pandemic. Industry-Wide Labor-Management Safety Committee Task Force. Available at: <> [Accessed 20 November 2020].

[7] 2020. Proposed Health And Safety Guidelines For Motion Picture, Television, And Streaming Productions During The COVID-19 Pandemic. Industry-Wide Labor-Management Safety Committee Task Force. Available at: <> [Accessed 20 November 2020].

[8] 2020. Safety Guidelines For The Film And Television Industry In Ontario. Film and television industry health and safety during COVID-19. [online] Ministry of Labour, Training and Skills Development of Ontario. Available at: <> [Accessed 20 November 2020].

[9] 2020. Safety Guidelines For The Film And Television Industry In Ontario. Film and television industry health and safety during COVID-19. [online] Ministry of Labour, Training and Skills Development of Ontario. Available at: <> [Accessed 20 November 2020].

[10] 2020. Inside Tyler Perry’s “Camp Quarantine”: How His Studio Wrapped Production Coronavirus-Free And Ahead Of Schedule. [online] Available at: <> [Accessed 23 November 2020].

Note: All opinions and advice expressed in this article are that of the author.

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