One of the key elements in the White Paper from the Industry-wide Labor-Management Safety Committee Task Force is the agreement among producers and unions to have an “autonomous” COVID-19 Compliance Officer for each production. The Compliance Officer will not be above-the-line talent, but will nonetheless play a starring role.

The White Paper defines the role of the Compliance Officer as an autonomous designee whose principal responsibilities will include overseeing and monitoring physical distancing, symptom monitoring and testing, disinfecting protocols, and PPE education, protocols, and adherence on set. Officers will be accessible at all times during work hours and will undergo specialized training on health and safety precautions, policies and procedures related to infection prevention, surface disinfection, and the use of PPE. Given the volume of federal, state, local, and now industry-specific pandemic safety laws and guidelines, coupled with the unique demands of Hollywood productions, the training is expected to be rigorous and time-consuming. 

It is noteworthy that the Compliance Officer will be autonomous – agreed upon by, but not reporting to, either the producer or the guilds, presumably with the power to temporarily shut down a production if necessary. While in the context of traditional labor relations the idea of an on-site and autonomous arbiter of workplace safety is unprecedented, Hollywood producers and guilds have embraced the idea that an autonomous Compliance Officer can resolve on-set COVID-19-related issues more efficiently than the traditional labor grievance and claim process. Moreover, the new Compliance Officer position appears designed to alleviate some of the COVID-19 safety burden for producers and directors, who traditionally share the responsibility for safety on set in accordance with collective bargaining agreements.

The introduction of this new role raises many questions, including how Compliance Officers will be selected, how they will be compensated, and the circumstances under which they can be removed. Other considerations are whether safety protocols will be applied uniformly across different productions, whether there will be a formal process for submitting complaints or one more akin to a baseball umpire calling balls and strikes, and how privacy concerns will be addressed. As these details are subject to ongoing negotiations among the producers and the guilds, we will continue to track them.