Common Missteps in Applying 29 CFR 1910.28 to Film and TV Productions

In the dynamic world of film and television production, safety is paramount. Yet, even the most seasoned professionals can stumble when it comes to adhering to 29 CFR 1910.28, the regulation that mandates fall protection. This piece dives into the common mistakes made on set, offering insights and strategies to ensure your production stays safe and compliant.

Understanding the Basics of 29 CFR 1910.28

First off, let's get one thing straight: 29 CFR 1910.28 is not just a suggestion; it's the law. It requires employers to provide fall protection for employees working at heights of four feet or more in general industry, including film and TV production. The regulation covers a range of scenarios from working on scaffolds to climbing ladders. But, as straightforward as it may seem, misinterpretations abound.

Mistake #1: Assuming All Sets Are the Same

One common error is treating every set like a cookie-cutter operation. I've seen crews on sound stages apply the same fall protection strategies they use outdoors, without considering the unique hazards of indoor environments. Remember, each location has its own quirks. A scaffold used on a rooftop might not be suitable for an indoor set where space is at a premium.

Mistake #2: Overlooking Temporary Structures

Film sets are notorious for their temporary nature. From hastily erected platforms to makeshift ladders, these structures often get overlooked when it comes to fall protection. But here's the deal: if it's four feet or higher, it falls under 29 CFR 1910.28. We've got to ensure that even the most transient of setups is up to code.

Mistake #3: Neglecting Training and Awareness

You'd think everyone on a film set would know the drill, right? Wrong. I've encountered countless situations where crew members, even those with years of experience, weren't fully versed in fall protection protocols. Regular training isn't just a nice-to-have; it's a must-have. And it's not just about ticking boxes; it's about fostering a culture of safety that permeates every level of production.

Mistake #4: Misjudging the Height Threshold

Here's where things get tricky. Some folks think if they're just a smidge under four feet, they're in the clear. Nope. The regulation is clear: four feet or more, and you need fall protection. I've seen productions skimp on safety gear, thinking they're safe because they're working at 3 feet 11 inches. Don't be that production.

Strategies for Staying Compliant

So, how do you avoid these pitfalls? Start with a thorough risk assessment of every set. Use personal protective equipment (PPE) like harnesses and guardrails, and make sure they're up to OSHA standards. And don't forget about the human element. Engage your crew with regular safety briefings and drills. Based on available research, individual results may vary, but one thing's for sure: proactive safety measures can significantly reduce the risk of accidents.

For those looking to dive deeper, the OSHA website offers detailed guidance on 29 CFR 1910.28. Additionally, organizations like the Safety on the Set provide resources tailored specifically to film and TV production safety.