Fire Safety at Production Locations; Production Location Fire Safety Manager Certificate of Fitness; and Production Location Fire Safety Manager Training Courses

Online comments: 78

• David T. Salvador

  Add “Assistant Location Managers” to the list of job titles in § 113-14 Production Location Fire Safety Manager Certificate of Fitness (c)(1).

  Comment attachment
  IBT-817-RL-FDNY-Proposed-Rules-re-Fire-Safety-at-Film-Production-Locations-11-01-2023-for-City-Record-publication.pdf

  Comment added November 28, 2023 11:35am

• Judi Kovacs

  Please see the attached list of question from a production studio client of ab3 Safety LLC.

  Comment attachment
  FDNY-Proposal_Questions-Final.pdf

  Comment added December 6, 2023 12:41pm

• Joe Guest

  I am a film producer, DGA unit production manager, and former NY Location Manager. It is clear to me that these critical efforts to address safety on film sets has been crafted without the necessary and proper and careful consideration and consultation with film & tv industry experts, union leaders from IATSE & the DGA as well as other stakeholders ie MPAA representives.
  Please send this back to the drawing board and this time bring everyone together in a room before drafting regulations that are onerous to imlement, wrong and don’t actually improve safety. The Mayor has assembled a film & tv Advisory Council to address issues EXACTLY like this. Call them first and take it from there. Thank you.

  Comment added December 7, 2023 12:00pm

• Michael Kriaris

  It is my understanding that the problem the proposed legislation is trying to address is the potential physical modification and storage within a location that may be encountered by a responding Fire company. It does not.

  Notification, communication, contact info and the up-to-date physical status including diagrams and photos of each location given by FIlm Productions to the local responding will provide information above and beyond what they would typically have when responding to a call that is not a “filming location”

  Comment added December 8, 2023 12:41am

• Rafael Lima

  Fire safety is paramount in film and television production because everyone needs to get home safely and the show literally can’t go on if something goes up in flames. However, unilaterally enforcing a Fire code without any consultation or input from our very accommodating industry will lead to drastic breakdowns in understanding, communication, and ultimately adherence to the rules. The FDNY and the film and tv production community all want the same thing: better fire safety on sets. But creating a substantial workforce of Fire Guards required to cover the multitude of workspaces for a production will create a host of problems that will be extremely difficult for productions to be able to manage. This will ultimately deter filmmaking in NYC, which will adversely affect thousands of New Yorkers, which I can’t believe is the FDNY’s intended goal. Please pause this effort and let’s incorporate thoughtful dialogue about how to upgrade the fire safety on our sets. Thank you!

  Comment added December 8, 2023 8:57am

• THOMAS WHELAN

  I am a producer, unit production manager, and former location manager in the film and television production business in New York. I am a member of the Directors Guild of America.

  I invite everyone to review the joint DGA-SAG response from March, 2023 which respectfully and thoughtfully lays out a strong argument to review and re-consider the proposed rules.

  I have worked with my colleagues in the DGA to draft new requirements for Studios to employ dedicated safety supervisors on every production. In our proposals, fire safety will be a prominent area of their responsibilities. A new Safety Supervisor pilot program, modeled on new programs passed in California, is now being developed and will be implemented by the major Studios in New York in the next two years.

  In the nearer term, many improvements can and should be made in the area of fire prevention and safety. There would not likely be any meaningful objection to expanded rules that would require more attention to construction materials and methods, egress, fire extinguishers, and improve communication with the FDNY. The proposed rules, however, go too far too fast.

  A typical television or streaming series production in New York is building, rigging, scouting, and shooting in multiple locations each day across the city. Under the proposed rules a minimum of 3-5 fire safety managers would be required full-time each day. With over 100 productions going on simultaneously in the city, there would be an immediate need and requirement for hundreds of certified fire safety managers.

  Will the Studios be willing to bear the new financial burden imposed by hiring 3-5 new full-time employees? Even if the biggest-budgeted shows decide they can, it would put many modestly- and low-budgeted productions out of business and looking for other cities to base their operations.

  Cost is not the only or even the main concern. Where will these new people come from? How long will it take to train the hundreds of people needed day one?

  Perhaps the City and the FDNY can take a step back and reconsider these rules, and consult with the Studios and their producers, production and location managers. Some real-world experience and inspection of actual locations and production methods may reveal that significant improvements can be made with less onerous and costly rules and precautions, focusing more on location conditions and situations that warrant close attention, and less on routine, less hazardous ones.

  If these rules are on track to be adopted as currently drafted, at the very least the City and FDNY should roll them out incrementally over a period of time that will allow the productions to adjust and to allow time to identify and train the hundreds of new personnel that will be needed to comply.

  Comment added December 8, 2023 10:06am

• Carla Raij

  I am a NY based Film Producer, Production Manager and ex-Location Manager with almost 29 years of experience working in this amazing city. Safety is paramount to all of us in our industry. As one of the film industry’s on set leaders, who is equally responsible for the logistical and financial components, I think the proposal as drafted is premature for approval. I believe we really need to work together and drill down a plan that is more efficient, and yes, less costly. Thank you for your consideration.

  Comment added December 8, 2023 10:42am

• Andrew Saxe

  To Whom it may Concern….

  My name is Andrew Saxe. I’ve been in the NYC film & TV industry for over 30 years. I am a film producer, DGA unit production manager, and former NY Location Manager. I have regularly worked closely with the FDNY explosives unit when there was ANY question of fire safety on set. Our qualified local 52 SPFX teams have ALWAYS worked in conjunction with FDNY to ensure safety on set. It is clear to me that these critical efforts to address safety on film sets has been crafted without the necessary and proper and careful consideration and consultation with film & tv industry experts, union leaders from IATSE & the DGA as well as other stakeholders ie MPAA representatives.

  Please send this back to the drawing board and this time bring everyone together in a room before drafting regulations that are onerous to implement, wrong and don’t actually improve safety. The Mayor has assembled a film & tv Advisory Council to address issues EXACTLY like this. Call them first and take it from there. Thank you in advance for your consideration.

  Comment added December 8, 2023 11:00am

• Dana Kuznetzkoff

  It takes a lot of time and resources to run a successful production. Most of that time is spent on health and safety – fire safety is incorporated into every aspect of filming from opening the production offices, setting up the construction shop and designing and building sets and then tearing them down. Risk Assessment is required for each individual location – identifying potential hazards and putting safety measures in place to ensure your production and individuals are safe.
  Communicating any risks and measures put into place with the entire team are paramount to a smooth, safe and successful shoot.

  Horrifically, it took a tragic fatality to make known a failing in location filming – and as a result, any designs and modifications to an existing structure must be always available. Codifying this is a good start to ensuring that local firehouses are always aware of any set construction nearby.

  These proposed rules offer many improvements for fire safety in film production, however there are certain proposals put forth that must be explored further with the input of studio safety managers, local unions, the Directors Guild, the MPAA, location managers and producers – all of whom have the industry expertise to ensure all safety measures are properly addressed.

  The City has a Film & TV Advisory Council made up of leaders in the industry with impeccable reputations. This Council is used as a task force for city leaders and community organizers when there is an issue specific to the film & TV industry that needs to be explored (and understood).

  I implore you to please review your proposals with the industry experts and hear from the experts directly how some of these proposals simply do not work.

  Together, you will find solutions that will have a positive impact on the FDNY, the film & TV industry in NY and ensure all set safety efforts are successful.

  Comment added December 8, 2023 12:18pm

• Jason Farrar

  I am a NY-based film/television Unit Production Manager and have been working in production since 1997. My colleagues (many with comments listed below) and I have spent countless hours discussing and implementing safety plans. It is an integral part of our job responsibilities. We are always looking for ways to improve our safety procedures. We are collaborative and thoughtful. Unfortunately, this unilateral code change is neither. Please bring our industry leaders, organizations, unions, and guilds into the discussion before passing a code change that hurts more than it helps. Thank you.

  Comment added December 8, 2023 3:19pm

• Nick Thomason

  I have worked in the NYC Film/Television industry for over 23 years. Everyone on our crews takes fire safety very seriously. The use of actual flames i rare and there is never one without a crew member standing with a fire extinguisher next to it off camera.

  These proposed regulations are onerous and will affect the number of productions in NYC. We will not be able to find qualified people and the studios will not be able to pay for the 3-5 people per production it will require. Coming out of the strikes by the WGA and SAG-AFTRA – we need every job we can get at this point.

  I’m urging the FDNY to work with the NYC film community to come up with a solution that works for everyone. We all want the same thing – a safe workplace for our cast and crews to work in and for the FDNY to never have to come to any of our sets.

  Comment added December 9, 2023 12:23pm

• David Chambers

  I have worked for well over 20 years in the film industry within the Location Department and/or as a DGA Unit Production Manager or Producer. All roles that are responsible for various aspects of safety on set.

  While safety is ALWAYS a top priority and concern, I feel that this proposal is premature and can be greatly modified and/or improved to both assist with practical safety concerns and be more pragmatic and logical as applied to the film industry.

  I strongly urge you to delay this proposal until there has been sufficient communication with our industry leaders (especially the Directors Guild of America and the newly formed Film & Television Advisory Council) to understand and better implement fire-related safety practices that will make more sense and be ultimately more successful. The valid training and sufficient safety background of the proposed ‘Production Location Fire Safety Managers’ is one of many concerns I have about this new proposal.

  Filmmaking is an undertaking grounded in cooperation. Let’s work together and create a plan that is more practical, yet also increases the level of fire safety on sets. Thank you for your consideration.

  Comment added December 9, 2023 1:00pm

• Demian Resnick

  The proposal as written is overreaching and seemingly created without much practical knowledge or consideration of film and television production in New York. What is proposed here does not make it any safer and instead forces unneeded and burdensome regulations on the industry. Whatever safety concerns this has been born out of need to be addressed in conjunction with the working men and women who are in the field everyday on shows along with their labor unions and guilds and the City Film Office that work hand in hand with them. Passing this as currently drafted would be a mistake and would harm this vital local industry that is still getting back on its feet after two massive shutdowns in the last three years due to Covid and strikes. Please consider more feedback from the industry itself before enacting these new regulations.

  Comment added December 9, 2023 3:28pm

• Aaron Levine

  I am a film producer and DGA unit production manager. It is clear to me that these critical efforts to address safety on film sets has been crafted without the proper and careful consideration and consultation with film & tv industry experts, union leaders from IATSE & the DGA as well as other stakeholders ie. MPAA and AMPTP representives.
  Please send this back to the drawing board and this time bring everyone together in a room before drafting regulations that are onerous to implement don’t actually improve or address real safety concerns which vary case by case. The Mayor has assembled a film & tv Advisory Council to address issues exactly like this one. Please engage them first before instituting such costly and burdensome requirements. Thank you.

  Comment added December 10, 2023 8:27pm

• Dan Welch

  Typically, the most senior member of a Location Department which is on set is an Assistant Location Manager (ALM), with extensive knowledge of the location: including but not limited to the electrical panels, fire panels, staging and filming areas, extinguishers, sprinklers, alarms and all exits.
  The ALM, on a daily basis, supplies the production with filming permits, communicates with city agencies as well as production department heads Art Department, Construction and Special FX.

  The ALM should be added by name to the list of qualifying positions listed in § 113-14 Production Location Fire Safety Manager Certificate of Fitness, subsection (c) (1) Qualifications.

  Question: § 113-14 Production Location Fire Safety Manager Certificate of Fitness, subsection (c ) (5) – “Other qualifying knowledge, training and experience acceptable to the Department.”

  Would ALM’s be considered knowledge enough with the proper training and experience to meet subsection (c) (5) qualifications, quoted above?

  Would ALM’s whom already hold a “certificate of fitness” from the FDNY be grandfathered as a Production Location Fire Safety Manager?

  Comment added December 11, 2023 10:46am

• April Taylor

  As a Unit Production Manager and former Location Manager and NYC resident working in film & TV production in New York City for [X] years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 8:21pm

• Donna Bloom

  As a Unit Production Manager and NYC working in film & TV production in New York City for over 30 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 8:25pm

• M. Blair Breard

  As a Producer, Unit Production Manager and NYC resident working in film & TV production in New York City for 31 years, I implore the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. We recognize the importance of safety – it’s the most important aspect of our work – but these proposed rules are onerous, and would destroy film and television production in New York, as the financial burden would be too much. How would the city even be able to train and staff the number of people being proposed? Restaurants, construction and most businesses aren’t required to have this level of cost and safety supervision, which makes it feel like this industry is being targeted. We don’t want to give the studios yet another reason to say no to filming in new York.

  Comment added December 11, 2023 8:57pm

• Megan Shaffer

  As a UPM working in film & TV production in New York City for the last 15 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:01pm

• E Pellegrini

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 10+ years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:04pm

• Gilana Lobel

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 18 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:06pm

• Amanda Slater

  As a Producer, Unit Production Manager and former 1st Assistant Director working in film & TV production in New York City for 28 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:12pm

• Suk Yi Mar

  As an Asst. Unit Production Manager, former Location Manager and NYC resident working in Film & TV production in New York City for over 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. Thank you.

  Comment added December 11, 2023 9:12pm

• John Fedynich

  As a DGA Unit Production Manager/Producer and former Location Manager working in film & TV production in New York City for over 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:27pm

• Daniel Hank

  As a Producer and Unit Production Manager as well as a NYC resident working in film & TV production in New York City for 30 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. The FDNY plan as proposed is recklessly irresponsible. We need a better plan and well trained people to provide the staffing.

  Comment added December 11, 2023 9:35pm

• Jared Goldman

  As a Producer and Unit Production Manager and NYC resident working in film & TV production in New York City for 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:46pm

• Erin

  As a Unit Production Manager working in film & TV production in New York City for 16 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:49pm

• Michael Ciliento

  As a Line Producer working in film & TV production in New York City for 19 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 9:52pm

• Rachel Cates

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 17 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 10:01pm

• Jason Sokoloff

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 15 + years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns that led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 10:03pm

• William (Bill) Carraro

  As a Producer / Unit Production Manager and NYC resident for many years, I am in support of increased safety measures that will help benefit residents, production crews and of course members of the FDNY and or 1st responders who may be party to advising safety issues on productions or for those who may be called on in the event of an emergency. I have worked in NY film & TV production in New York City since the mid 1980’s and take seriously the need to provide a safe working environment. That said, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. There is no doubt that the proposal intends to ensure a process for increased communication and safety procedures for all parties involved. However, when examining the new proposal, and how it would be adapted to the realities of production, the rules appear to require a fire safety manager to be physically present at every permitted location, regardless of activity at those locations. This approach does not seem necessary for many situations, and it does not seem realistic for the volume of productions and permitted locations in this city.
  With additional dialogue between the parties involved there is an opportunity to more effectively address the concerns which led to the creation of these regulations. Again, as one of the many participants who promote safety on productions and also relies on this industry’s presence in NYC for employment, I respectfully request that the FDNY consider rethinking this proposal while working closely with the Industry’s Film & TV Production Council; to discuss further and understand better the unique structure of the industry and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. We know we have much we can learn from the FDNY and I believe a collaboration built on mutual goals will result in a more meaningful lasting set of guidelines. Thank you for your consideration.

  Comment added December 11, 2023 10:25pm

• Ulises Rodriguez

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 10:41pm

• Hilary Kehoe

  As a DGA Unit Production Manager (and NYC resident) working in film & TV production in New York City for almost 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 10:46pm

• Kristyn Macready

  As a unit production Manager and NYC resident working in film & TV production in New York City for 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 10:56pm

• W Sell

  As a Producer and UPM working in film & TV production in New York City for 21 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations.  As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.  

  Comment added December 11, 2023 10:59pm

• Lynn powers

  As a Assist Unit Production Manager/Location Manager and resident of Brooklyn, working in film & TV production in New York City for over 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:03pm

• Stephen Lippross

  As a Unit Production Manager and New York City resident working in film & TV production in New York City for [X] years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:08pm

• James D Lee

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 26 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:08pm

• Teddy Au

  As a Unit Production Manager and Producer working in film & TV production in New York City for 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:12pm

• Rob Striem

  As a Unit Production Manager and former Location Manager working in film & TV production in New York City for 30 years, and a member of the Director’s Guild of America since 2001, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:17pm

• Becky Glupczynski

  As a Unit Production Manager and NYC resident if in film & TV production in New York City for 28 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:22pm

• Meghan Wicker

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 20+ years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:25pm

• Rosemary Lombard

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for over 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:27pm

• Ellen Athena Catsikeas

  As a NYC resident working in Film and TV production for almost 19 years as an Assistant Production Manager and Location Manager, I urge the FDNY to reconsider this proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations.
  We are especially concerned with who these people are going to be, how the city will train them, and whether the city will be able to come up with the amount needed that is being proposed.
  As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:37pm

• Audra Gorman

  As a Unit Production Manager/Location Manager working in film & TV production in New York City for 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 11, 2023 11:38pm

• Moe Bardach

  As a Film Producer, DGA Unit Production Manager, former DGA Location Manager and full time New York City resident working in film & TV production in New York City for 36 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. Thank you

  Comment added December 11, 2023 11:57pm

• Lila Yacoub

  As a Producer and Unit Production Manager working in film & TV production in New York City for over 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 12:05am

• Arlen Valdivia

  On behalf of our member companies, the Motion Picture Association (MPA), we respectfully submit our comments to Proposed Rule 3 RCNY §325-01. We share the Department’s goal of ensuring fire safety as a continued production priority. However, the proposed regulations do not fully consider film and television production’s unique nature or volume and will significantly impact the industry.

  New York City is one of the leading filming destinations in the world. Many iconic films and television series are filmed in New York City, specifically on location, which means that the buildings and streets of the City serve not only as crucial settings but also as temporary backlots to every scripted production that films there. The Department’s proposed rules of having a designated fire safety manager physically present for each production location would significantly impact production. In discussion with our member companies and the Mayor’s Production Council, each production would potentially require numerous fire safety managers per day per location to fulfill the requirements of the draft rules.

  The duties and responsibilities of a fire safety manager cannot be assigned to the obligations of existing crew members as these additional responsibilities would need to be bargained during labor negotiations. Consequently, productions would need to hire a third-party person(s) with qualifications as outlined in the draft regulations. We are concerned that, based on the qualifications required, there may not be sufficient candidates to fulfill these roles and who are willing to bear the responsibility of personal liability should an accident happen. Accordingly, we request that the department consider alternative models and afford a reasonable timeline for compliance.

  We understand FDNY’s need to balance fire safety and prevention and the realities of on-location filming in the City. The draft rules contain provisions that would create additional safety levels by requiring more communication between productions and having productions comply with NFPA 140. However, there is no practical way to meet the Department’s intent to have a fire safety manager always present at each location. With more than 80 productions filming in the City at any given time at various locations and conducting different activities, this requirement would be untenable, and, in many cases, the local firehouses would have hundreds of points of contact with staff constantly changing with varying levels of consistency, potentially leading to catastrophic confusion.

  We believe we can achieve the Department’s goal and fulfill the intent of Local Laws 33 and 34 by working with the FDNY Explosives and Entertainment Unit – who have a deep knowledge of how production works as they already review film permits to determine when the presence of a firefighter is needed – to determine which activities require the presence of a fire safety manager. Alternatively, productions can dedicate a fire safety manager per production as part of a holistic safety team. In conjunction with the safety measures already implemented on productions, this person will monitor fire safety on set. They would coordinate with the appropriate FDNY personnel to communicate their activity and potential fire safety concerns, as they will have the complete picture of filming activities for the entire production.

  Both the Mayor and the Governor have been vocal about the importance of this industry to the state and local economy, and the regulations, as drafted, have the serious potential to drive production out of the City and even New York. As FDNY works to finalize the rules, the MPA urges the Department not to rush the process and to coordinate with the Production Council and its members to discuss a meaningful and realistic approach to these rules that will foster fire safety, as intended by Local Law 33 and 34, while maintaining a thriving film and television community.

  Comment attachment
  FDNY-Proposed-Regulations_MPA-Letter_12.12.23.pdf

  Comment added December 12, 2023 12:07am

• G.Yeaton

  As a Producer, Unit Production Manager and NYC resident working in film & TV production in New York City for 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule appears to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 12:30am

• Guy Efrat

  I am New York based film and television Unit Production Manager, a former Location Manager and an NYC resident. I have been working in production for over 25 years. I am in support of increased safety measures that will help benefit residents, production crews and of course members of the FDNY and or 1st responders who may be called on in the event of an emergency. Safety measures, communication and safety logistics on stage and on location is paramount to all of us in our industry. The proposed new rule 3 RCNY §325-01 as drafted seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. A proposal that was drafted without input from industry safety experts, union leaders, stakeholders, or any official industry collective representation. It does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of improving the safety of all New Yorkers.

  Comment added December 12, 2023 1:17am

• Peter Sabat

  As a Producer/Unit Production Manager working in film & TV production in New York City for over 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 5:35am

• Helen Robin

  I am a film producer and DGA unit production manager. It is clear to me that these critical efforts to address safety on film sets has been crafted without the necessary and proper and careful consideration and consultation with film & tv industry experts, union leaders from IATSE & the DGA as well as other stakeholders such as MPAA representatives.
  Please send this back to the drawing board and this time bring everyone together in a room before drafting regulations that are onerous to implement, wrong and don’t actually improve safety. The Mayor has assembled a film & tv Advisory Council to address issues EXACTLY like this. Call them first and take it from there. Thank you.

  Comment added December 12, 2023 5:47am

• Todd Judson

  As a Production Supervisor working in film & TV production and living in New York City for several years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 6:10am

• Mari Jo Winkler

  As a Producer adn Unite Production Manager living and working in film & TV production in New York City for 30 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 6:15am

• Amy Herman

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for [X] years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 6:22am

• Dhana Gilbert

  I am a Producer and Unit Production Manager and have worked in the NYC Film/Television industry for over 30 years. Everyone on our crews takes fire safety very seriously. The use of actual flames is rare and there is never one without a crew member standing with a fire extinguisher next to it off-camera.

  These proposed regulations are onerous and will affect the number of productions in NYC. We will not be able to find qualified people and the studios will not be able to pay for the 3-5 people per production it will require. Coming out of the strikes by the WGA and SAG-AFTRA – we need every job we can get at this point.

  I’m urging the FDNY to work with the NYC film community to come up with a solution that works for everyone. We all want the same thing – a safe workplace for our cast and crews to work in and for the FDNY to never have to come to any of our sets.

  Comment added December 12, 2023 6:31am

• igor srubshchik

  As a producer and NYC resident working in film & TV production in New York City for 28 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 6:45am

• Leslie Gyson

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 22 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As a UPM I take safe working conditions extremely seriously. As a rule we implement safety considerations in every decision of filmmaking. I implore the the FDNY to come back to the table to work together with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:01am

• neri tannenbaum

  As a Production Manager and NYC resident working in film & TV production in New York City for [X] years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:13am

• Kevin Muller

  As an associate producer working in film & TV production in New York City for 15 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:19am

• Adam J Brightman

  As a Unit Production Manager working in film & TV production in New York City for over 30 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:23am

• Chris George

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:29am

• Joseph White

  As a producer and son of a fireman, working in film & TV production in New York City for 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 7:42am

• Carol Cuddy

  As a Producer and Unit Production Manager working in film & TV production in New York City for over 40 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 8:01am

• Diana Schmidt

  This new policy will only chase work away from NY.

  Comment added December 12, 2023 8:09am

• Jake Brown

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 12 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 8:14am

• Randy Manion

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 25 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Thank you.

  Comment added December 12, 2023 8:24am

• Canella Williams-Larrabee

  As a Unit Production Manager and working in film & TV production in New York City for nearly 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations.  As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.  

  Comment added December 12, 2023 8:53am

• KIP D MYERS

  As a Unit Production Manager working in film & TV production in New York City for [X] years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 9:04am

• Melissa Gelernter

  As a member of the NY production community for over 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 9:08am

• Francesca Mannix

  As a Unit Production Manager and Brooklyn resident working in film & TV production in New York City for close to 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01.
  Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single indoor and/or enclosed outdoor permitted location, regardless of activity at those locations. Depending on who is able to qualify as a Fire Safety Manager and as the position is currently listed, this quickly becomes unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations.
  As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council and other industry groups (local unions and MPA to name a few) to understand and develop alternative rules along with a planned roll out for application that will best serve the goal of keeping all New Yorkers safe. Thank you.

  Comment added December 12, 2023 9:08am

• Brittany Sugarman

  As a Unit Production Managerand NYC resident if applicable working in film & TV production in New York City for years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 9:27am

• Jennifer Jimenez

  As a Unit Production Manager and NYC resident working in film & TV production in New York City for 6 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 10:03am

• Brendan ORourke

  As a Location Manager working in film & TV production in New York City for 20 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 10:09am

• Jim Miller

  local 52 40 year member

  Comment added December 12, 2023 10:10am

• Kelsi Russell

  As a Unit Production Manager working in film & TV production in New York City for 16 years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe.

  Comment added December 12, 2023 11:48am

• Michael Walbrecht

  On behalf of Warner Bros. Discovery (WBD), we respectfully submit our objections to Proposed New York Fire Department Rule 3 RCNY §325-01. WBD, which includes companies such as HBO, Warner Bros. Television, and Warner Bros. Pictures, has a long history of production in New York City and most recently have filmed such shows as And Just Like That, Succession, and Gossip Girl. Most of our productions in New York rely heavily on the use of location filming that highlights the City’s various neighborhoods, making the city a character in their storylines. We very much appreciate the partnership with the city departments we work with every day to ensure filming goes smoothly.

  On set safety is a top priority for our company, and we share the Department’s goal of ensuring fire safety protocols are prioritized. However, we believe that the proposed requirement to have a designated fire safety manager physically present for each location would negatively impact production. The regulation fails to consider the volume of production work in the city and does not fully distinguish between activities that require oversight versus the majority of instances where it is not necessary. The one-size-fits-all approach will only serve to deter production in New York City. Using a current WBD production in NY, we have calculated that the production could require a minimum of 22 separate fire safety manager assignments per week for each episode. WBD typically has between five and ten productions in the city each year, so you can see how quickly the number of managers assigned would become very difficult to staff, which would only serve to hinder the safety and efficiency the Department is seeking. We believe the proposal will cause further confusion in communication during emergency situations where there would be multiple points of contact, will not improve safety on set in the manner this proposed rule intends, and will add substantial costs to each production which will only serve to deter productions from the City.

  We also share the same concerns that other studios, the Motion Picture Association, and the Mayor’s Production Council have expressed that existing crew members cannot fill these roles as it would need to be bargained during labor negotiations with our unions.

  The film industry is a vital contributor to our city’s economy and cultural identity. Any regulatory framework must consider the nuances of this unique sector while ensuring the safety and well-being of cast, crew, and the public. WBD strongly believes the Department’s goals can be achieved while balancing the logistical and cost issues. We ask that you work with us and the Mayor’s Production Council in crafting a solution that will keep production working in New York City.

  Comment attachment
  12.11.23-WBD-Comment_FDNY-Rule_dsMW.pdf

  Comment added December 12, 2023 1:59pm

• Jill Footlick

  As a Unit Production Manager and Producer (and NYC resident) working in film & TV production in New York City for 25+ years, I urge the FDNY to reconsider its proposed new rule 3 RCNY §325-01. Translated to the realities of production, the rule seems to require a fire safety manager to be physically present at every single permitted location, regardless of activity at those locations. This is unrealistic for the volume of productions and permitted locations in this city and does not effectively address the concerns which led to the creation of these regulations. As one of the many workers who promote safety on productions and relies on this industry’s presence in NYC for employment, I ask that the FDNY work with the Industry’s Film & TV Production Council to understand and develop alternative rules that will best serve the goal of keeping all New Yorkers safe. We support the FDNY and thank you for supporting the many union members that rely on this vital industry.

  Comment added December 12, 2023 4:49pm