The Smoke-free Premises etc. (Wales) (Amendment) Regulations 2012

Contribution by Machine Productions Ltd  to the Consultation

Thank you for this opportunity to express our views. Machine Productions Ltd is a company producing TV and film drama, based in Treforest. We have been running for 5 years, and have produced a single film, Zig Zag Love, and a 26 part childrens drama for CITV, Tati's Hotel. We have series awaiting decisions with C4 and CBBC.

To be frank, the competition to get drama commissions  for a Welsh based company, is already so tough that we must not be less competitive as a place to shoot drama, or as place to attract external productions into Wales. WAG is putting considerable effort and money into supporting creative businesses - this is much appreciated and it would be regrettable if anything worked against this.

• Is there a commercial need for this amendment to exempt performers from smoke-free requirements?

• Will this amendment achieve its aim of supporting the television and film industry in Wales?                             

Anything that makes Wales in any way uncompetitive with next door England for inward investment is a problem. Clearly, there are no statistics about a future impact. But currently popular TV programmes that have portrayed indoor smoking would include Sherlock, Stella (both shot in Wales) The Hour, Ripper Street, The Paradise, Call the Midwife, Downton Abbey, Leaving, Bletchley Circle, Parades End, Mrs Biggs... and many others. We must not disadvantage Wales in making period drama in particular.

• Is there sufficient clarity about the circumstances in which the exemption applies?

Yes, I believe so.

• Do the conditions offer adequate protection to other performers, production staff and members of the public? 

Yes, I believe so. It is still legal to smoke in any domestic environment, we all live in a world of car emissions and chemicals. The exposure is relatively tiny. But I would have no problem with team members registering a personal objection and stepping away from the scene.

• Might there be any unintended consequences of introducing this exemption?

The impact on TV and Film seems to me to be an unintended side effect of core workplace legislation designed, very rightly, to protect workers in bars, restaurants, office, factories and other indoor spaces where they might be exposed every day to routine amounts of passive or secondary smoking.

• What health policy considerations are relevant to this amendment?

I would suggest that the health impact on people in Wales from poverty and unemployment is a very much more major problem than one actor with one cigarette in a studio or interior location. I believe any arguments about representation or imitative behaviour have no place in a debate about workplace safety legislation. What might be disliked  next - car crashes, stunt  fights, use of weapons, bad language, anti social behaviour, arson, rape, murder, excessive drinking, drug abuse, anorexia ....

Jane Dauncey, Director

Machine Productions Ltd