Working Under COVID: Advice for Factual Directors

COVID-19 has left no industry or profession untouched. The film and TV industry was itself hit particularly hard by a complete production shutdown very early on during the crisis.

As the industry now tentatively returns to work, Directors UK wants to support its members as creative leaders so they can play a central role in ensuring that the return to production is as safe and creative as possible.

To that end, we have created Working Under COVID: Advice for Factual Directors, a detailed resource to help directors navigate their way through production during this “new normal” we now find ourselves in. We hope to equip directors with important questions and thinking points that will help inform a COVID-safe approach throughout every stage of production.

The resource will help directors to:

  • identify the key safety issues and questions to ask;
  • contribute to the preparation of risk assessments;
  • contribute to the preparation of safety procedures;
  • identify any potential failings or oversights;
  • raise concerns without fear of sanction;
  • escalate serious safety issues promptly;
  • use their knowledge, expertise and professional discretion to determine whether the risks and risk management procedures that are in place are acceptable or not.

Our resource is divided into two sections. In Fundamentals we cover points that are relevant throughout the entire production process. Where appropriate, we also include advice and best practice on dealing with specific issues. In Stages of Production we raise the relevant thinking points and questions that directors should be asking themselves at each distinct production stage.

The industry has already worked collaboratively on two pieces of high-level guidance:

  1. Pact TV Production Guidance: Managing the Risk of COVID-19 in Production Making
  2. British Film Commission: Working Safely During COVID-19 in Film and High-end TV Drama Production

We refer to these two documents throughout our own resource but aim to guide directors towards the information and advice that is most relevant to them.

The document is purposefully non-prescriptive so as to encourage its use as a resource to aid the director’s planning process, and to help directors to assess the support offered by existing production company protocols.

This resource has been created in collaboration with Prash Naik (Legal Counsel), First Option Safety Consultants, the Directors UK Factual Working Group and the Directors UK Pay and Working Conditions Committee. See Contributors section for more information.

Download Working Under COVID: Advice for Factual Directors

Factual directing

As mentioned above, the industry has already worked collaboratively on two pieces of high-level production guidance (see Useful Resources section). However, both of these documents are largely focused on film and drama and we therefore recognise that factual directors are in particular need of additional support.

While our resource is relevant to directors working in all genres, we have put a specific emphasis on the framework of factual directing. Factual directors often have to take on a lot of the responsibility themselves for ensuring that their production is COVID-safe; they work in less controlled environments (which therefore have higher COVID-related risks), with non-professional contributors and with smaller production teams.

There are several key points that emerge within our resource, all of which adhere to existing good practice stipulations for factual directing:

  • Avoid lone working
  • Ensure that reasonable working hours are maintained
  • Establish clear lines of responsibility throughout every stage of the project and its production

These stipulations have always been important, even in non-COVID times, but are now critical within the current circumstances. Adhering to these key practices will help decrease further risks across a production.

Download Working Under COVID: Advice for Factual Directors

Key considerations

There are several overarching considerations that underpin all the thinking points and advice that feature in our resource:

  • COVID-19 is a potentially deadly virus that raises significant safety issues for all directors. This must be borne in mind at all times. The infectious nature of the virus means that we each have a responsibility not only to ourselves but to our families, friends, colleagues, contributors and the wider community to ensure that we act responsibly and do not place ourselves or others at risk of harm.
  • It is not possible to remove all risk of infection. It is important to understand that the nature of the virus is such that, at this time, it is not possible to remove all risk. Current government and industry guidelines are designed to minimise the risk of infection but they cannot remove the risk altogether.
  • You need to carefully consider whether you are prepared to accept the level of risk that exists. If you have serious concerns because you or a family member are shielding or fall within a group that is at higher risk of infection, then you need to carefully consider whether you are prepared to accept those risks or not. No one should be pressured to work under conditions that place them at risk of harm but equally directors will need to satisfy themselves that the conditions under which they have agreed to work are sufficiently safe.
  • Increased risk assessments and safety procedures are here to stay. These are unprecedented and challenging times. The situation can change quite rapidly, and as infection rates begin to rise regional lockdowns are already coming into force with very little notice. There’s also a continual possibility of further national lockdown restrictions being announced. It is therefore essential that everyone accepts that risk assessments and safety procedures around COVID-19 are going to remain an essential part of the production landscape in the immediate future and beyond.
  • Collaboration is key to making these safety procedures work. Broadcasters, production companies and freelancers are all learning how to adapt to and develop the best safety practices. All will have to collaborate more closely and engage on these issues from a safety, legal, financial, editorial and ethical point of view. While directors are on the front line of these decisions, and are ideally placed to facilitate that collaboration, it is important to remember that all parties share responsibility for protecting the individuals working on their productions and the contributors that they interact with.
  • Directors should be fully consulted on risk assessments and safety procedures. As an integral part of the production and the creative lead on location, directors carry the responsibility for creating the strongest possible content in the safest possible manner. Therefore directors will often be best placed to advise whether safety measures are practicable and to monitor whether they are being adhered to. Directors should also be consulted on any material changes made to these procedures.
  • Lone shooting (where only one production team member is on location) should be the exception under normal conditions, and even more so now. Even under ordinary circumstances, filming alone can seriously compromise the safety of directors and should therefore only be authorised in certain exceptional, highly controllable situations. During the current pandemic, no director should be unsupported on a shoot; they should be supported by at least one other member of the production. Paired crews can look after each other, better manage the safety of contributors and work in tandem to identify and minimise risks in a way that a lone worker cannot – especially if this lone worker is a self-shooting director whose attention is focused on many different things. Teams can also help manage safe equipment handling and share production and safeguarding tasks so as to reduce the amount of time needed at a location. Budgetary pressures should never be a justification for cutting corners on the safety of crew members or contributors.
  • Long working hours should be the exception even under normal conditions, and even more so now. Even under normal conditions, directors often work extremely long hours and are expected to keep several plates spinning at once, all of which can result in levels of fatigue that pose a risk to health and safety. Broadcasters, production companies and freelancers must all recognise now that the responsibility of managing additional safety protocols will further increase the pressure on freelancers. These safety procedures may have an impact on filming schedules and filming plans should therefore be adjusted to allow adequate time for production team members and contributors to work within the new structures. Directors and crew must not be subjected to unreasonable time pressures and the consequent risks to safety. Budgetary pressures should never be a justification for cutting corners on the safety of crew members or contributors.
  • Directors should familiarise themselves with all the available guidance. As mentioned above, there are now several pieces of high-level government and industry guidelines and you can find these in the Useful Resources section below. In addition, most broadcasters and some production companies have developed their own protocols as well (which should be made available to you when you work with them). Directors will need to familiarise themselves with these various resources before production begins, but our resource will help you to navigate your way through the areas of most relevance to you.

Download Working Under COVID: Advice for Factual Directors

Risk assessments and safety procedures

Risk assessments and safety procedures are referred to throughout our resource and the other pieces of industry guidance. They are key tools in any production environment and their importance has only increased during the COVID-19 pandemic. Directors can make a significant contribution to the preparation of these procedures, and so our resource includes a detailed section on pages 7-8 which breaks down exactly what these processes require, both under ordinary circumstances and during the pandemic.

Download Working Under COVID: Advice for Factual Directors

What to do if safety procedures aren’t being followed

At the heart of our resource is the overriding principle that every member of a production has the right to raise concerns about safety (especially where risk assessments are inadequate or where safety procedures are lax) and for prompt and appropriate action to be taken to address those concerns without fear of sanction.

We have therefore created a flowchart, which you can find on pages 48-50 of Working Under COVID: Advice for Factual Directors, which outlines how to escalate these kind of concerns. You will see that there are multiple opportunities at which issues can be addressed and risk levels reduced. And at all stages, Directors UK is on hand to offer advice and support.

Futher questions

The coronavirus pandemic is still ongoing and conditions on the ground are going to change, often quite rapidly. This resource is designed to help directors navigate industry and production company guidance regardless of any updates that are made to those individual procedures.

However, we recognise that best practice is developing all the time, and questions are going to arise as the situation changes.

If you have any questions about working under COVID that aren’t addressed by this advice, or questions about the advice itself, Directors UK is here for you. Please email us at [email protected] and we’ll provide any help or guidance that we can.

Download Working Under COVID: Advice for Factual Directors


Prash Naik

Prash Naik is the former General Counsel for Channel 4.

He now lives in Sydney, providing pre-publication advice to TV, film and digital producers internationally. He advises through the London media law practice Reviewed & Cleared, his Sydney-based law practice Prash Naik Consulting, and as General Counsel to the Doc Society, a non-profit foundation based in London and New York that supports independent documentary filmmakers globally.

First Option Safety Consultants

As the leading health and safety provider in the film and entertainment industry, First Option have been at the forefront of supporting production to restart in the face of COVID-19.

First Option were part of the BFC’s production subgroup and the UK broadcasters’ development of COVID-19 production protocols, and they have worked with many of the US studios and SVoDs to create UK versions of their COVID procedures. They have also created their own COVID-19 Production Manual, The Yellow Book, which is currently being used across the sector.

They partnered with ScreenSkills to create the COVID-19 awareness e-learning course, and their own Managing COVID-19 Risks on Productions and COVID-19 Supervisors online courses have trained over 7,000 production staff to date.

They produce a weekly COVID-19 dashboard briefing for clients and regular technical notes on various COVID matters, from testing to hygiene.

The First Option Stores Team have supplied PPE and sanitising products (including 100,000 masks) since the pandemic began, and their in-house and associate team of safety consultants have been supporting productions onsite to develop and implement COVID protection measures, ensuring cast and crew members are kept safe on set.

Directors UK Pay and Working Conditions Committee

Directors UK Factual Working Group

The Directors UK Pay and Working Conditions committee explores practical issues relating to the daily working lives of directors and helps to identify ways to create positive change. The committee is made up of Directors UK members, and contributors work in all genres of TV production. They have an interest in health and safety, working conditions, contracts, pay and remuneration, and working hours. The committee reports directly to the Directors UK Board.

The Directors UK Factual Working Group is a subgroup of the Pay and Working Conditions Committee that focuses on the unique challenges of factual production.

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