Screen Actors Guild Letter to DOL
On December 17th SAG submitted their response to the Department of Labor’s proposed rule.  They have recently published this letter on their web site ~ Click for Letter.  We encourage you to read the letter in its entirety.

Synopsis of SAG’s Letter to DOL
Introductory Statement about SAG’s history and national presence.

Physician’s Certification

  • We strongly object to <Restatement of Rule>
  • Lots of questions posed
  • Restatement of purpose of Child Performers Advisory Board/Eating Disorder Committee
  • “It is not clear that the proposed physical examination requirement will effectively prevent eating disorders or increase access to treatment.”
  • Suggests alternative:  education campaign/video that parents watch prior to permitting

Responsible Person

  • SAG contract allows for “sight and sound” but non-union children “will be disadvantage.”
  • Need to create variations in rule that account for types of employment ~ live theatre vs. film/TV
  • “We urge you to include language allowing the parent to be within sight and sound of their child at all times and to clarify and strengthen the definition of “responsible person.”
  • Concern about Group Permit ~ no provision for the children’s ages, no mention of “sight and sound” or working conditions.

Education Requirements

  • Concern that regulation is unclear as to when on-set education is required.
  • Suggestion:  “if a child actor has two consecutive days and it is subsequently determined that there will be more days that occur within a 30 day period, then the child shall be tutored each day he or she is on set for the remainder of the production.”
  • Note that SAG has seen previous drafts of the rule. “This language was included in several other previous drafts.”
  • SAG supports privately held for-profit company ~ On-Location Education’s brief.

Trust Account

  • Restatement of Rule
  • “Regardless of a person’s age, employers should never be able to hold the earnings of a worker.  The proposed language allows employers to hold a portion of the performer’s earnings creating interest income, and increases the possibility that children’s earnings will be lost.  Payment to the Child’s Trust Account should be made concurrent with regular pay.”
  • Note that SAG has seen previous drafts as “references to live theatre employment have been removed from these draft regulations.”
  • Want rule variation for live theatre including different work hours and “sight and sound” requirements.

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