Environmental Health and Safety Laws for the Theater Professional
Theatre Technology, where creativity meets compliance. As an practitioner, understanding Environmental Health and Safety (EHS) regulations is not optional; it is essential to your career and, more importantly, to the safety of your cast, crew, and audiences.
This guide provides the regulatory framework that governs theatrical production in the United States. Whether you become a technical director, stage manager, scenic designer, or production manager, these regulations will shape every production you mount.
This guide is simply to be used as a reference to point you in a direction to pursue additional information, much of which is either available on entertainingsafey.com or linked within this document.
Part 1: Federal Environmental Laws
Federal environmental laws establish the legal framework within which theatrical operations must function. While some of these may seem distant from the stage, they directly impact your paint shop, scene shop, costume construction, and production storage facilities.
Clean Air Act (CAA) of 1970
The CAA regulates air pollutants from stationary and mobile sources. For theater professionals, this means:
- Spray painting operations in scene shops must control volatile organic compounds (VOCs)
- Solvent use for cleaning and adhesive applications falls under CAA jurisdiction
- Asbestos abatement in historic theater renovations requires CAA compliance
- Fog and haze machine emissions may require consideration in enclosed spaces
Clean Water Act (CWA) of 1972
Amended in 1977, the CWA regulates point source discharges into U.S. waters. Theater applications include:
- Proper disposal of scenic paint wash water
- Dye discharge from costume shops
- Storage requirements for petroleum products used in equipment maintenance
CERCLA (Superfund) of 1980
The Comprehensive Environmental Response, Compensation, and Liability Act, known as Superfund, addresses past releases of hazardous materials into the environment. The Superfund Amendments and Reauthorization Act (SARA) of 1986 expanded this coverage. Key points for theater professionals:
- Personal liability extends to individuals responsible for releases
- Historic theaters may be located on or near Superfund sites
- Proper documentation of hazardous material handling protects you legally
Toxic Substances Control Act (TSCA) of 1976
TSCA restricts human and environmental exposure to highly toxic substances including:
- Polychlorinated biphenyls (PCBs), found in older lighting equipment ballasts
- Asbestos in older theatrical curtains and insulation
- Lead-based paints in historic scenic elements
Resource Conservation and Recovery Act (RCRA) of 1976
RCRA provides the “cradle-to-grave” framework for hazardous waste management. This directly impacts scene shops and production facilities.
Hazardous Waste Characteristics:
- Ignitability: Flash point below 140°F (60°C). Many scenic paints and solvents qualify.
- Corrosivity: pH below 2.0 or above 12.5. Some cleaning agents and dyes qualify.
- Reactivity: Unstable substances, including certain pyrotechnic materials.
- Toxicity: Determined by TCLP analytical testing.
Generator Classifications:
- Large Quantity Generator: >1,000 kg per month
- Small Quantity Generator: 100-1,000 kg per month
- Very Small Quantity Generator: <100 kg per month
Part 2: Occupational Safety and Health Administration (OSHA)
OSHA, established in 1970, operates under the U.S. Department of Labor and represents the primary regulatory body affecting day-to-day theatrical operations. All OSHA requirements are published under Title 29 of the Code of Federal Regulations (29 CFR).
The General Duty Clause
Section 5(a)(1) of the OSH Act states that each employer shall furnish employees a place of employment free from recognized hazards likely to cause death or serious physical harm. This clause applies even when no specific OSHA standard exists for a particular hazard.
The Entertainment Industry and OSHA
OSHA does not maintain entertainment industry-specific standards. Instead, theatrical operations fall under General Industry Standards (29 CFR 1910) and, during load-in, load-out, and construction, Construction Industry Standards (29 CFR 1926).
The OSHA Alliance with the United States Institute for Theatre Technology (USITT) and the International Alliance of Theatrical Stage Employees (IATSE) addresses fall, electrical, ergonomic, and other hazards present in the entertainment industry through information sharing, guidance development, and training resources.
State-Specific Requirements
Several states have implemented entertainment industry-specific safety requirements:
Nevada Assembly Bill 190:
As of 2018, workers in scenery, props, rigging, wardrobe, hair/makeup, audio, lighting, projection, and camera departments must complete OSHA 10-Hour training. Supervisors require OSHA 30-Hour certification. Refresher training is required every five years.
California Labor Code Section 9251:
California requires entertainment event vendors to certify that employees meet skilled and trained workforce conditions, including completion of Cal/OSHA 10-Hour or OSHA 10-Hour/General Entertainment Safety training. Department heads and leads must hold certification from the Entertainment Services and Technology Association (ESTA) Entertainment Technician Certification Program (ETCP).
Key OSHA Standards for Theater
Fall Protection (29 CFR 1910.21-32 and 1926 Subpart M):
While OSHA recognizes that guardrails at stage edges are impractical, theatrical employees must still be protected from fall hazards. Personal fall arrest systems, positioning devices, and safety nets may be required for work at heights. Riggers working at 75 to 150 feet require appropriate fall protection equipment.
Personal Protective Equipment (29 CFR 1910.132-138):
Employers must assess workplace hazards and provide appropriate PPE including eye protection, hearing protection, respiratory protection, and full-body harnesses for fall protection.
Hazard Communication Standard (29 CFR 1910.1200):
2024 Update: As of July 19, 2024, OSHA has aligned the Hazard Communication Standard with the 7th revision of the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The Material Safety Data Sheet (MSDS) has been replaced by the Safety Data Sheet (SDS) with a standardized 16-section format. Chemical manufacturers must comply by January 19, 2026, with mixture compliance required by July 19, 2027.
Part 3: Department of Transportation (DOT)
DOT regulations govern the transportation of hazardous materials and are codified in Title 49 of the Code of Federal Regulations (49 CFR Parts 171-180). For touring productions, these regulations are essential.
Key DOT Requirements:
- Proper packaging and container specifications for hazardous materials
- Marking, labeling, and placarding of vehicles transporting hazardous cargo
- Uniform Hazardous Waste Manifest (EPA Form 8700-22) for hazardous waste shipments
- Training requirements for HAZMAT employees (49 CFR 172.700-.704)
UN Numbers:
Four-digit identification numbers assigned to hazardous materials for transportation purposes. These numbers appear on vehicle placards and shipping documents. Theatrical touring productions transporting pyrotechnics, compressed gases, or flammable materials must display appropriate UN numbers.
Part 4: ANSI E1 Entertainment Industry Standards
The Entertainment Services and Technology Association (ESTA) Technical Standards Program develops American National Standards Institute (ANSI) accredited standards specifically for the entertainment industry. These standards represent the consensus of industry professionals and establish best practices.
Critical ANSI E1 Standards
| Standard | Description |
| ANSI E1.4 | Manual Counterweight Rigging Systems. Establishes design, installation, inspection, and maintenance requirements. |
| ANSI E1.6-1 | Powered Hoist Systems. Requirements for electric chain hoists in entertainment applications. |
| ANSI E1.2-2021 | Aluminum Trusses, Towers, and Structural Components. Design, manufacture, and use requirements. |
| ANSI E1.21-2024 | Temporary Structures for Outdoor Entertainment Events. Referenced by 2024 International Building Code. |
| ANSI E1.42 | Safety Standard for Entertainment Lifts. Covers stage lifts, orchestra pit lifts, and similar equipment. |
| ANSI E1.47-2020 | Recommended Guidelines for Entertainment Rigging System Inspections. Establishes annual inspection requirements. |
Important: ANSI E1.47-2020 states that manually operated and motorized rigging equipment should be inspected annually or immediately after installation, alteration, or repair. Click here to schedule your inspection today.
ETCP Certification
The Entertainment Technician Certification Program (ETCP), administered by ESTA, provides professional certification for entertainment industry technicians. Certifications include:
- Theatre Rigger
- Arena Rigger
- Entertainment Electrician
- Portable Power Distribution Technician
More information about ETCP Certification is available at http://etcp.esta.org
Part 5: National Fire Protection Association (NFPA)
The NFPA develops voluntary consensus standards that are frequently adopted by state and local jurisdictions as law. For theatrical professionals, NFPA standards are not optional*; they form the regulatory basis for fire safety in most venues.
Critical NFPA Standards for Theater
NFPA 101: Life Safety Code
The foundational document for means of egress, assembly occupancy requirements, and emergency procedures. Every theater professional should understand its provisions for assembly occupancies.
NFPA 160: Standard for the Use of Flame Effects Before an Audience (2021)
Governs the design, manufacture, and operation of flame effects in theatrical productions. Requirements include:
- Permit and approval requirements from the Authority Having Jurisdiction (AHJ)
- Flame effect operator qualifications (minimum age 21)
- System classification and control requirements
- Fire protection provisions and standby personnel requirements
- Documentation and operating procedure requirements
NFPA 1126: Standard for the Use of Pyrotechnics Before a Proximate Audience
Provides requirements for protection of property, operators, performers, support personnel, and viewing audiences where pyrotechnic effects are used indoors or outdoors.
NFPA 701: Standard Methods of Fire Tests for Flame Propagation of Textiles and Films
The standard specifically reserved for theatrical curtains, draperies, and hanging fabrics. Most jurisdictions require stage curtains and scenic fabrics to meet NFPA 701 testing criteria.
Flame Retardancy Classifications:
- FR (Flame Retardant): Topically treated fabric. Water-soluble treatment that may wash out. Requires annual field testing per NFPA 705.
- DFR (Durably Flame Retardant): Chemical compounds bound to fibers. Withstands up to 25 washes. Annual testing recommended.
- IFR (Inherently Flame Resistant): Manufactured from non-combustible elements. Permanent flame resistance for the life of the fabric. Annual testing still recommended.
NFPA 140: Standard on Motion Picture and Television Production Studio Soundstages, Approved Production Facilities, and Production Locations
Addresses fire protection, property protection, and life safety in production environments including live entertainment venues used for filming.
*NFPA documents are voluntary consensus standards but often incorporated into state/local code, at which point compliance is legally required; the practical effect for theaters, as described, is accurate.
Part 6: Environmental Protection Agency (EPA)
EPA regulations are codified in Title 40 of the Code of Federal Regulations (40 CFR) and cover air, water, solid waste, hazardous waste, pesticides, and other environmental concerns.
Key EPA-Administered Statutes
| Statute | Theater Application |
| CAA | Scene shop spray painting, solvent use, asbestos abatement |
| CWA | Paint wash water disposal, dye discharge, petroleum storage |
| RCRA | Hazardous waste management from scene shops, costume shops |
| CERCLA | Liability for hazardous substance releases, Superfund site proximity |
| EPCRA | Emergency planning, community right-to-know reporting for hazardous materials |
| FIFRA | Pesticide management in venue maintenance |
SARA Title III: Emergency Planning and Community Right-to-Know Act (EPCRA)
Triggered by the 1984 methyl isocyanate release in Bhopal, India, EPCRA requires:
- State and local emergency response plans for extremely hazardous substances (EHS)
- Business notification to emergency planning entities of EHS presence and quantities
- Reporting of planned and unplanned environmental releases
- Public access to hazardous substance information
Part 7: International Treaties and Agreements
For theater professionals working internationally or with touring productions, understanding global environmental agreements provides essential context.
Paris Agreement (2015):
Replaced the Kyoto Protocol as the primary international climate agreement. The United States rejoined the agreement in 2021. Productions may face increasing pressure to demonstrate carbon neutrality and sustainable practices.
Montreal Protocol:
Regulates ozone-depleting substances. Impacts theatrical refrigeration systems, foam insulation, and certain aerosol products.
Basel Convention:
Controls transboundary movement of hazardous wastes. Relevant for international touring productions disposing of waste materials.
Part 8: Key Definitions
Hazardous Materials (DOT 49 CFR 171):
Any substance or material in any form or quantity which poses an unreasonable risk to safety, health, and property when transported in commerce.
Hazardous Substances (EPA 40 CFR 302):
Any substance designated under the Clean Water Act and CERCLA as posing a threat to waterways and the environment when released.
Hazardous Substances (OSHA 29 CFR 1910.120):
Every chemical regulated by EPA as a hazardous substance and DOT as a hazardous material.
Extremely Hazardous Substances (EPA 40 CFR 355):
Chemicals determined by EPA to be extremely hazardous to a community during an emergency spill or release due to toxicity and physical/chemical properties.
Hazardous Chemicals (OSHA 29 CFR 1910):
Any chemical that would be a risk to employees if exposed in the workplace.
Hazardous Wastes (EPA 40 CFR 260-281):
Discharged materials regulated by EPA because of public health and safety concerns under RCRA authority.
Safety Data Sheet (SDS):
The standardized 16-section document that replaced the Material Safety Data Sheet (MSDS) under the GHS-aligned Hazard Communication Standard. SDSs provide comprehensive hazard information for chemical products.
Conclusion: Building a Safety Culture
Understanding EHS regulations is the foundation of professional theatrical practice. As you progress through your theater program and into your career, remember that safety is not a constraint on creativity; it is what enables creativity to flourish without tragedy.
The regulatory landscape continues to evolve. Stay current through professional organizations like USITT, ESTA, and IATSE. Consider pursuing ETCP certification. Most importantly, develop the mindset that every member of your production team deserves to go home safely at the end of every rehearsal and performance.
The show must go on, but only when it can go on safely.
Resources
Regulatory Agencies:
- OSHA: www.osha.gov
- EPA: www.epa.gov
- DOT PHMSA: www.phmsa.dot.gov
- NFPA: www.nfpa.org
Professional Organizations:
- USITT: www.usitt.org
- ESTA: www.esta.org
- IATSE: www.iatse.net
- ETCP Certification: etcp.esta.org
Standards:
- ESTA Technical Standards: tsp.esta.org
- ANSI Webstore: webstore.ansi.org
References
Entertainment Services and Technology Association. (2020).
ANSI E1.47-2020: Entertainment technology – Recommended guidelines for entertainment rigging system inspections. ESTA.
National Fire Protection Association. (2021). NFPA 160: Standard for the use of flame effects before an audience. NFPA.
National Fire Protection Association. (2024). NFPA 701: Standard methods of fire tests for flame propagation of textiles and films. NFPA.
Occupational Safety and Health Administration. (2024, May 20). Final rule to amend the hazard communication standard. U.S. Department of Labor. https://www.osha.gov/hazcom/rulemaking
Occupational Safety and Health Administration. (n.d.). OSHA alliance: USITT and IATSE. U.S. Department of Labor. https://www.osha.gov/alliances/usitt-iatse
U.S. Environmental Protection Agency. (n.d.). Laws and regulations. https://www.epa.gov/laws-regulations