BBC Safety Standard - Weapons in Scripted Productions

The Health and Safety at Work etc. Act 1974 requires you to minimise the risk of workplace injuries “as far as is reasonably practicable”. This includes taking steps to protect employees and others from injuries relating to the undertakings of the
employer.

The Management of Health and Safety at Work Regulations 1999 require risk assessments to be undertaken and arrangements for safety including emergencies to be established.

The Provision and Use of Work Equipment Regulations 1992 require employers to provide suitable equipment, training, storage and maintenance of equipment provided at work.

The Firearms Act 1968 https://www.legislation.gov.uk/ukpga/1968/27/contents

The Guide on Firearms Licensing Laws https://assets.publishing.service.gov.uk/media/6787c8615a1adfc79556d
f5f/Firearms_Guide_-_November_2022.pdf

The hazards associated with firearms and subsequent risks include;

• Loss of the firearm [any type of firearm] – leading to unlawful use, locking down of areas where weapons have been lost causing local disruption and use of police / emergency services time / resources.

• Apart from being lost or stolen the biggest risk associated with anon-functional ‘prop’ firearm will be dropping the prop or losing control during an action sequence – leading to someone being struck by the prop which may lead to soft tissue / eye / minor bruising type injuries.

• Incorrect or mistaken use – leading to accidental discharge potential nips / traps in firearm mechanisms [replica weapons] or impact injuries from projectiles leaving the firearm [blank firing or live firing weapons]. This may also cause stress or trauma for those who witness or suffer the injuries.

• Misperception of the public – leading to trauma, stress and police being called to locations where filming and use of firearms [any type of firearm] are being used. Potential armed response units putting members of the production and public at risk.

• Loud noises above the Noise at Work Regulations action levels –leading to acute or chronic hearing damage [blank / live firing weapons].

• The use of black powder type weapons – leading to the risk of flashes, small debris in the air and the potential for burns where skin is close to the ignition of the black powder or eye irritation /small particles or smoke entering the eye. Without controls in place the residual risk of using any type of firearm, live or replica, taking into account the risk of a replica being used unlawfully is High.

To reduce the risks associated with the use of live and replica firearms to an acceptable level you must:

Identify the specific firearm requirements you need for your production in order for a risk assessment to be completed. The information you will need will include the type of firearm[s], shotguns, air operated weapons or prop replicas. The risk assessment will need to be completed by a competent person. This standards sets out overarching BBC risk assessment requirements for managing firearms in television production.

Once the type[s] of weapon[s] have been determined based on the hierarchy of controls below the level of support can be assessed;

• eliminating the use where possible e.g. via the script
• reducing the risk by selecting non firing [blank or live weapons including air operated weapons]
• reducing mechanical working replicas for prop non-functioning weapons [no moving parts preventing nips / traps etc.]
• reducing the number of firearms required on the production [to help manage storage and widescale distribution]
• selecting locations with a view to management control [who may observe their use / presence]
• You must also establish that those you propose to hold / use any live or replica firearm are the type of person who is permitted to do so under the Firearms Act 1968 [Section 21 identifies restrictions for some individuals who have been convicted of specified sentences or terms of imprisonment]

Competent source of advice

You must engage a competent person or persons to help you assess the risk and establish controls as part of a more specific firearm or ‘prop’ firearm risk assessment. This individual must have due diligence checks carried out by the production to establish they are the right person to support the risk assessment process. Based on your selection and range of firearms this may not be one individual.

Where a replica non functioning ‘prop’ weapon is used the production may have the competence and resources available to them in order to manage the use and reduce the risks to an acceptable level.

In the incidence of using a prop non-functioning weapon the residual risk is based;

• Relatively minor impact injuries during action sequences; or
• The weapon being lost and used unlawfully putting the public and potentially emergency services at risk of stress, trauma or injury in relation to action taken by members of the public or emergency services to remedy a situation where a live weapon is perceived to be present.

To mitigate this risk the notification of the use, especially if the prop maybe seen by members of the public [but recommended in all cases], is to notify the police in order to obtain a CAD number. Other controls will include the correct storage and allocation of the prop. The prop should be handed out when required for filming and taken back into lockable
storage as soon as possible after the filming requirement has ended.

This role may be undertaken by a nominated responsible person who is clearly identified on the risk assessment undertaken by production [if there is a change in this role the risk assessment should be updated it is not recommended that a number of names are identified as the NRP as this could lead to confusion and mistaken actions on the production.

The benefits of having a person familiar with the use and handling of the weapon should not be overlooked both from a general handling and editorial perspective.

Competent person[s] often referred to as an Armourer

Where a replica, mechanically functioning, live or blank firing firearm, shotgun or air powered weapon are proposed for use competence checks should include;

• The individual [where a company is used pay particular attention to the individuals that are proposed to support the production] holds any necessary licence or permit for the appropriate firearms
• Evidence of instructor qualifications can be useful
• Evidence of range safety training can be useful. The individual has relevant experience in the handling and use of the appropriate weapons
• There is adequate insurance cover provided by the individual or company
• Experience in the production process may help the shoot progress more efficiently.
• The individual should be able to provide example risk assessments that demonstrate they identify the specific hazards, who may be harmed, the risks associated with the specific firearms, how they will be controlled, how risks will be communicated to those at risk and when the risk assessment may need to be reviewed. The risk assessment should follow the HSE [Health and Safety Executive] 5 steps to risk assessment.

The competent person risk assessment should develop on the overarching assessment of risk prepared by the production and identified in this Standard.

The risk assessment must be recorded on Safety Hub.

Communication of risk assessment findings

The risk assessment controls must be communicated to the people who are at risk. With regards to members of public who are at risk the primary means of protection are informing the police so that any subsequent calls are supported by the police informing members of public that they are aware of the artistic use of firearms.

Letters of intent must be letter dropped in the local area to inform people of the intended use of firearms where they may be seen by members of the public.

Those on the production who are at risk from the use of firearms must be informed of the controls that are in place to protect them. This may differ depending on the role an individual has for example,

• Actors will need to know how to use and handle the weapon correctly
• Those behind the camera will need to know what personal protective equipment is needed e.g. hearing protection
• Locations may need the CAD reference for a location host / owner

Cooperation in delivering and overseeing the control measures.

It is likely that there will be combination of roles responsibilities shared between the production, nominated responsible person [where appropriate] and the armourer[s]. Where there is the requirement for shared responsibilities it must be clear what responsibilities are held by the relevant parties. For example;

• it should be the production who checks the criminal records status of those required to handle weapons in line with Section 21 of the Firearms Act.
• it should be the responsibility of the nominated responsible person to provide a prop weapon to an artist and then receive it back for stowage when not in use.
• It should be the responsibility of the production – delegated in many instances to the location manager for the letter dropping of the intent to use replica weapons in an area where members of the public may see their use. 
• It will be the responsibility of the production to obtain a CAD reference from the police, unless agreed in writing that the armourer will obtain the reference on behalf of and provide it to the production ahead of filming.

Where there is more than one competent person required due diligence checks should be carried out on each person.

Identify the need for firearms as early in production as possible. This will allow appropriate time for the controls to be established as part of the management process. In particular this will allow;

• Elimination and reduction of risk at the planning stages
• Early identification of the need for a nominated responsible person [where a non-functioning prop firearm is to be used]
• Early identification of the need for an armourer
• Vetting of proposed armourers in time for appropriate assessment of risk.
• Early checks on any persons required to use firearms or replicas in line with the Section 21 of the Firearms Act

Once you have established the need for firearms to be used and have vetted the armourer you should;

• Provide the armourer with or discuss with the armourer the type of firearms you know / think you need based on the script and interaction with the director / producer.
• Begin the specific risk assessment process in conjunction with the armourer.
• Engage with the armourer over their view on how long it will take to train someone in the use of the firearm based on the scripted action.
• Establish when training will be undertaken and schedule this so that it is clearly documented.
• Establish the handling procedures on set and any restrictions that are required.
• Identify the requirement for firearm use when scouting for locations in order to factor in any checks, documentation, arrangements etc. the location host / owner may require or you may need to implement [this may include additional security requirements, access control, exclusion zones, etc.]
• Consider the benefits of the armourer visiting the location prior to filming in order to help establish what safe zones may be necessary e.g. drop zone for clay pigeons and clearance distances for falling shot
• Identify who will need what level of briefings based on the level of risk they are exposed to.
• Identify what personal protective equipment may be necessary [and agree responsibility for providing it].
• Establish emergency arrangements e.g. who will report a lost firearm and to whom, what happens in the event of an accidental discharge, how a misfire will be dealt with, what if any additional first aid arrangements may need to be in place.
• Complete the risk assessment in conjunction with the armourer.
• Brief the necessary people prior use of firearms, replicas etc.
• Prior to use have a final check to make sure the controls are appropriate – this may be part of a run through without the weapons in play.
• Record who was briefed and in relation to what aspects of the controls identified in the task specific risk assessment – based on the controls identified in the management process.

Having established the need for the use of firearms early in production you could organise an awareness / briefing session with the competent person[s] for key members of the production who may need to know more e.g.

• In relation to training periods for artists
• Transportation and storage considerations based on the complexity of the firearm aspects of the production
• Restrictions that may be present such as location / area sizes that may be necessary
• Restrictions in use e.g. Firearm Act Section 21
• Editorial considerations such as:

                         *Period functionality of firearms

                          *Turnaround times for reloading / re setting

Compare proposed competent person arrangements to help establish the best level of support taking into account training, resources, experience, early engagement, quality of past management arrangements including the accuracy and content of risk assessments and to some extent cost [based on like for like provision but fluctuating fees].

Liaise with others over the experiences they have had with suggested contractors.

Take assurance on the provision of the support a contractor has provided by checking that procedures have met the risk assessment controls.

Engage an independent firearms specialist to coordinate armourers where large scale use of firearms is proposed. This will allow oversight and checking of systems by someone who is an expert.

There should be appropriate emergency arrangements in place for all work activities. The arrangements should be proportionate to the levels of risk. Under the Health & Safety [First Aid] Regulations and the Management of
Health and Safety at Work Regulations the employer must provide first aid.

In many cases an appropriate number of first aid at work trained individuals provided with a suitable first aid kit will be appropriate. Where the level of risk increases e.g. due to construction work, stunts, rigging at height, SFX
etc. There may need to be an increased number of first aid trained individuals or a higher level of cover e.g. paramedic.

The use of firearms alone will not necessarily increase the risk of injury e.g. if the replica mechanically functions but does not fire e.g. a shotgun that can open and close but cannot receive a cartridge that fires the risk will be around nips and traps in the opening and closing. A first aid trained individual should be adequate for this type of situation. Even where a live shotgun is used or firearms are used at training facilities across the country, such as clay shoots a first aid at work trained person should be adequate. Where the activity increases the risk e.g. running with a firearm, fighting, etc. then there will be
the requirement to assess the risk and establish if the production requires a higher level of cover.

There are recommendations on the level of cover 1 first aid trained person per 100 low risk workers, 1 per 50 medium risk workers and 1 per 20 higher risk workers. The level of training does not increase the number of people a
first aid trained person can support whether they are a first aider medic, nurse or doctor. Should also account for absence and illness so never only have one.