Most production companies in California have an Injury and Illness Prevention Program. It sits in a binder at the production office, was written for the company as a whole, and says very little about the abandoned warehouse in Vernon where the second unit is shooting a fight scene this Thursday. That gap is the problem. Title 8, Section 3203 requires the IIPP to identify and evaluate the hazards of each workplace, and a film set is a new workplace every time the company move happens. Producers, unit production managers, first assistant directors, and location managers are the ones who carry this obligation, and they are the ones Cal/OSHA will ask for the paperwork when someone is hurt.
What Section 3203 Actually Requires
The IIPP standard applies to every California employer and requires a written program with eight elements: responsibility, compliance, communication, hazard assessment, accident and exposure investigation, hazard correction, training, and recordkeeping. Two of those elements are inherently location-specific.
The hazard assessment element requires periodic inspections to identify and evaluate workplace hazards, including whenever new substances, processes, procedures, or equipment are introduced, and whenever the employer becomes aware of a new or previously unrecognized hazard. The hazard correction element requires that hazards be corrected in a timely manner based on severity, and that employees be protected in the interim. A company-level IIPP can establish who is responsible and how training works. It cannot evaluate the hazards of a location no one had seen when it was written.
Set construction on stages or at practical locations also falls under Section 1509, the construction IIPP requirement, along with the fall protection, scaffolding, and electrical rules that come with it.
Why a Production Is Different From a Factory
A manufacturing plant has the same hazards on Monday that it had on Friday. A production may shoot in a residential kitchen on Monday, a rooftop on Tuesday, a moving vehicle on Wednesday, and a riverbed on Thursday. Each of those locations brings hazards the base IIPP did not contemplate: unguarded roof edges, unknown electrical systems, wildlife, traffic, water, heat, confined attic spaces, and the structural condition of a building that has been vacant for a decade.
The crew changes too. Day players, background performers, local hires, and vendor personnel arrive without the training the core crew received. Section 3203 requires training for new employees, for new job assignments, and whenever new hazards are introduced. A documented location safety briefing at call time is how productions meet that requirement.
What a Site-Specific IIPP Addendum Should Contain
The practical solution is a company-level IIPP supplemented by a location addendum for each site, prepared before the company arrives. A good addendum is short, specific, and posted or available at the set. It should cover:
- The location address, dates of use, and the person on site with authority and responsibility for safety, typically the first assistant director with support from a set safety officer or consultant
- A written hazard assessment of the location itself: structure, access and egress, electrical, fall exposures, fire exits, hazardous materials found on site, weather, heat, terrain, and traffic
- The specific hazards of the scheduled work at that location: stunts, special effects, vehicles, animals, water work, aerial work, firearms, and rigging
- Controls for each identified hazard and who is responsible for verifying them before the first shot
- Emergency information: the nearest emergency room, ambulance access, the location of first aid supplies and the set medic, the muster point, and how the emergency action plan under Section 3220 applies to this site
- Heat illness prevention measures under Section 3395 when any work is outdoors, including water, shade, and the high-heat procedures
- The safety meeting record: who was briefed, on what, and when
The industry’s own safety bulletins, developed by the Industry-Wide Labor-Management Safety Committee, are widely recognized as the standard of care for stunts, firearms, pyrotechnics, vehicles, water, and many other activities. Referencing the applicable bulletins in the addendum and actually following them is the single most useful thing a production can do.
What a Cal/OSHA Inspector Looks For
Cal/OSHA inspections of productions usually follow an injury, a complaint, or a serious incident reported under Section 342. The inspector will typically ask for:
- The written IIPP and evidence it was communicated to the crew at this location
- Hazard assessment documentation for this location, not the generic one
- Safety meeting sign-in sheets and the content of the briefings
- Training records for the people involved, including day hires and background performers
- Stunt and special effects safety plans, permits, and the qualifications of the coordinators
- Fall protection, rigging, and electrical documentation where those hazards were present
- The accident investigation record, if the visit follows an injury
An inspector who receives a company IIPP with no location assessment and no meeting records has what is needed to cite a Section 3203 violation, and penalties can reach well into five figures per serious violation and higher for willful or repeat violations. When the injury was serious, the IIPP citation typically arrives alongside citations for the specific hazard involved.
Stunts, Pyrotechnics, and Special Effects
These are the activities that produce the injuries that make the news, and they demand the most from a site-specific plan. The production should be able to show, in writing, that a qualified stunt coordinator or special effects supervisor planned the sequence, that the plan was rehearsed and reviewed with the performers and the crew, that the location was inspected for the specific hazards of the sequence, and that a safety meeting was held immediately before the take.
Pyrotechnics in California require a licensed pyrotechnic operator under the State Fire Marshal’s program and a permit from the local fire authority having jurisdiction. Fire department standby is commonly required. Firearms on set, even those firing blanks, call for a qualified property master or armorer, controlled custody of every weapon and every round, and a briefing of everyone in the line of fire before any use. Every one of these activities also implicates Section 3220 emergency action planning and Section 3221 fire prevention, and the addendum should say how those plans apply at this location.
Practical Locations: The Hazards You Inherit
A practical location comes with whatever the owner left there. Older buildings frequently contain asbestos, lead paint, and mold; disturbing those materials for set construction or dressing can trigger Cal/OSHA’s asbestos and lead standards, including Section 1532.1 for lead in construction. Vacant industrial sites may have confined spaces covered by Section 5157, unmarked pits, energized equipment, and structural decay. Rural locations bring heat, uneven terrain, wildlife, and long distances to emergency care.
A technical scout that includes a safety walkthrough, with the findings written into the addendum, is far cheaper than discovering a rotten floor joist under a dolly track on the shoot day.
What to Do Now
- Confirm the company IIPP exists, is current, and names the people responsible for safety on each production.
- Build a location addendum template and require one for every location before the call sheet goes out.
- Add a safety walkthrough to every technical scout and record the findings.
- Hold and document a safety meeting at every new location and before every stunt, effects, or weapons sequence.
- Verify licenses, permits, and qualifications for pyrotechnics, firearms, and stunt coordination before the day, not on the day.
- Keep sign-in sheets, training records, hazard assessments, and the emergency plan together at the set so they can be produced within minutes.
McNeil Safety Consulting prepares production IIPPs and location-specific safety plans, walks technical scouts, and provides on-set safety oversight for productions across California. If your next company move is to a location no one has assessed, call (626) 546-9384 or learn more about our film and television safety services.