COVID-19 Production Guidelines - Vaccination
Summary Policy Changes
PASS guidelines will no longer require testing for fully-vaccinated individuals on set pending the adoption by the Cal/OSHA Standard Board of the proposed changes to the COVID-19 Emergency Temporary Standards on June 3.
This decision was reached in collaboration with public health, medical, legal, and industry experts. Our reasoning is based on updated regulatory guidance and evidence that vaccination is effective at significantly reducing the risk of transmission of COVID-19. However, each set is different, and performers and crew should always be free to request what they need to feel safe. Additionally, production studios should speak with an attorney about their particular situation before imposing a policy, as rules and regulations differ by local, county, and state municipalities.
All other safety protocols should remain in place — including symptom screening, social distancing, and face coverings.
FSC and PASS encourage everyone to get vaccinated as they are able, but we do not suggest requiring vaccination to work on set.
These are interim guidelines for fully vaccinated individuals that may change as knowledge about vaccination develops, more people become vaccinated, and the spread of COVID-19 changes in the population. The guidelines are meant to inform the health and safety practices on adult sets, but should be considered in the context of your production's specific needs.
What does “Fully Vaccinated” Mean?
A person is considered fully vaccinated 14 days after their second vaccine dose of Moderna or Pfizer, or 14 days after their first dose of Johnson & Johnson.
How Can Producers Verify Vaccination?
IMPORTANT: Employers, please note any medical records you request from people you hire need to be maintained for 30 years from the last date of employment. This includes viewing vaccination record cards.
Verification of vaccination status is something all employers and businesses are struggling with, as there is no centralized database where all records of vaccination are kept. While no method is without its challenges, you can verify vaccination in the following ways:
PASS
PASS is now able to verify vaccination status in its database. PASS participants who have had their vaccination status verified will now appear with a green checkmark in that field. Nothing will display for those who have not been verified.
PASS participants who want their vaccination status displayed in the PASS database will need to submit a copy of their ID and vaccination record cards. Information is stored on a secure server only accessible by PASS staff.
Vaccination Cards
This is likely the easiest way to verify vaccination status and seemingly current best practice. Vaccination cards are issued during your first vaccine appointment. The card will say the kind of vaccine, where it was received, and the date it was received. Some providers will also include the Date of Birth and Patient ID number, but not always.
If you have lost your vaccination card:
Contact your vaccination provider
If you are unable to contact your vaccination provider, contact your state health department's Immunization Information System to find out how to get a new one
Steps to Verify
Request to view ID and vaccination card of individual
Ensure name and DOB match, and that 14 days have passed since last vaccination dose (2 doses for Pfizer/Moderna, 1 for Johnson & Johnson.)
Production should record that vaccination was verified.
Applications
There are also a couple different applications that verify vaccine cards for you, which we have listed here. While this adds an additional step to the process, these check against state vaccine databases to ensure validity.
VaxYes
Type of system: Texts/Web Ppp
Steps to use: Enter phone number on website, text copies of vaccine card and photo id to them.
Steps to verify: The process is a little complicated – you have to scan the code, enter your phone number, enter the validation code they send you, then enter the person's first and last names and DOB to see their certificate.
ConfirmD
Type of system: phone app (iPhone and Android)
Steps to use: Sign up for app, upload vaccine card twice (in the case of verifying two shots), identification, and a photo of yourself.
Steps to verify: Use app to scan QR code in someone else's app.
Verification Platforms
There are a number of applications available that verify vaccination status. These work by linking to a specific health care account and accessing the records. While secure, there are significant interoperability concerns, which is why this might not be a solution for all people: not all vaccination sites maintain records, and those that do may not integrate with an application that can verify vaccination status.
Some examples of verification applications:
Healthvana
Residents of Los Angeles County who are vaccinated against COVID-19 can ask for a digital record. The county partnered with Healthvana to allow users to download the record to their Apple Wallet or a similar Google platform for airline travel or other purposes.
Carbon Health Health Pass
As part of the Carbon Health Vaccinate platform, the Health Pass is accessible to all patients who have been vaccinated at a Carbon Health-powered site, or have received a prior vaccination from the Carbon Health network of private and municipal partners.
Los Angeles city tapped healthcare startup Carbon Health to be the portal citizens use to book and manage vaccine appointments. It is also delivering digital records to patients. After a patient gets a vaccine, they'll receive an email with information about how to access their digital records.
Othena
Othena is being used for vaccine appointments at the county’s mass inoculation sites, including Disneyland. Orange County could easily update its vaccine appointment scheduling website, Othena, so that people who used it to get vaccinated could show anyone proof of their vaccination.
State Immunization Information System
Each state collects and stores vaccination information in its own Immunization Information System (IIS), which can be used as an official record. These databases typically need to be accessed by a medical healthcare provider or public health authority, though several states allow people to access their vaccination records directly. It can take a couple of weeks to process a request, so plan in advance. If you need help accessing your vaccination record, speak with your healthcare provider.
Medical Records Release from Vaccination Provider
If you were vaccinated by a healthcare provider, they should have maintained medical records which you can request a copy of if you contact them. Be aware that there are many places that are providing vaccines that are not maintaining medical records (like large events), so this may not be an option for everyone. Please note that there may be additional medical information that may be revealed on medical records, so we would recommend speaking with an attorney prior to using this verification method.
Can vaccination be required to work on a set?
Possibly, but the answer is complicated. We suggest speaking with an attorney if you are considering creating a mandatory vaccination policy. That being said, the California Department of Fair Employment and Housing has issued the following explanation:
“Under the FEHA, an employer may require employees to receive an FDA-approved vaccination against COVID-19 infection so long as the employer does not discriminate against or harass employees or job applicants on the basis of a protected characteristic, provides reasonable accommodations related to disability or sincerely-held religious beliefs or practices, and does not retaliate against anyone for engaging in protected activity (such as requesting a reasonable accommodation).”
DFEH Employment Information on COVID-19, March 4, 2021
