The Company Placing Studio Teachers Also Serves Productions

Studio teacher Jean Marie Donnelly halted a Gettysburg scene in early July 2024 after two local boys turned up without work permits. She was the rare adult on that field who could say no, and she still answers to a placement company that also serves the production.

Fifteen teachers, child labor coordinators and parents later described nearly two dozen alleged safety and schooling breaches on sets in California, Georgia, Florida, Illinois, New Mexico, North Carolina and other states. The pattern they describe is not a missing rulebook. It is a paycheck that runs through the same office as the permits.

Two Boys, a Campfire and No Permits

Nearly 1,000 Civil War reenactors packed Daniel Lady Farm in Gettysburg, Pa., for the 161st anniversary of the battle, with cannons, muskets and bayonets on the grounds. A crew for Kathryn Bigelow’s Netflix feature used the pageant as a backdrop. Donnelly was there as studio teacher and designated child welfare worker for a 10-year-old actor.

The production, she said, invited two young local boys in Union costumes, who had come with their grandparents, to appear with her minor. She asked for child labor permits. There were none, which she said violated Pennsylvania labor law, and she said the production also lacked legal parental permission to film them.

The pair carried what looked to her like muskets. The plan, as she described it, was for them to run near a burning campfire with the young actor, through several takes as the temperature edged toward 100 degrees. She saw no armorer to inspect the gun props, and she refused to let the scene proceed.

If something happened with these muskets or they pushed my kid into the fire, that’s a health and safety issue.

Jean Marie Donnelly, studio teacher, in a SAG-AFTRA complaint

She put the episode in a text to a supervisor and in that union complaint. Several people close to the Netflix production acknowledged they did not have work permits for the local children. They and the boys’ grandparents disputed her account of the danger, saying the boys carried cap guns that did not need an armorer, that there were no plans to film near a campfire, and that they complied once she stopped the shot.

WHAT WE KNOW

• The permits: People close to the production said the two local boys had no child labor permits.
• The stop: Donnelly, a California-certified studio teacher, refused the scene and documented the halt to a supervisor and to SAG-AFTRA.
• The prop master: Neal W. Zoromski, a veteran prop master, said even a toy gun introduced on a film still has to be vetted and cleared.

WHAT IS UNCONFIRMED

• The muskets: Donnelly described gun props with no armorer. A Netflix spokesperson said the minors brought their own toy wooden muskets, that safety personnel inspected them, and that no minors handled weapons or stood close to a fire.
• The fire: Donnelly said the boys would run near a campfire. Production-side accounts said there were no plans to film near one.

A Netflix spokesperson called her account “inaccurate” and said production safety personnel inspected the toys “in an abundance of caution.” Donnelly still treats the stop as the point of the job. “Those two boys would have gone right into the movie,” she said. She could push back, she added, because California certifies her as a studio teacher with the power to pull a minor off a set, and she and union representatives argue that California rules travel with a California child and a California-based company. “Was the entire cast and crew mad at me? Yes, but… I had to be vigilant.”

On Location Education Works for the Production Too

The largest supplier of those teachers is On Location Education, a Westchester County, N.Y., company that says it has placed educators on thousands of productions, including Black Adam, School of Rock and The Marvelous Mrs. Maisel. Alan Simon, a former New York City substitute teacher and aspiring actor, founded it in 1982 after a friend got him a tutoring job on the Broadway musical Frankenstein. The Screen Actors Guild had just set national schooling rules for minors: a teacher on set, and three hours of instruction a day when a child works three or more consecutive days. That rule created a business.

OLE now says it is incorporated in nine states plus Canada and the United Kingdom. Its public pitch is not only tutoring. It also coordinates work permits, welfare specialists, labor-law guidance and chaperones, and it tells producers it will take the hassle out of work-permit paperwork for productions. The same vendor that sends the adult who can halt a shot also files the papers that let the child be there.

ON LOCATION EDUCATION’S SET SERVICES

Teachers who work with the company are teachers as independent contractors, not permanent staff. OLE keeps a national database and calls people when a project appears. They can decline a job. They can also be dropped from the next one with no grievance process that looks like a staff job.

Justin Gross, a studio teacher who has worked for OLE, put the money trail in one sentence. “They’re getting a handsome fee from production, providing a teacher. And yet, if there’s an issue that production has caused, they don’t back up the teacher in that situation because it’s biting the hand that feeds them.” He said the company failed to back him on Amazon’s Paper Girls in Illinois in 2021, when he pushed back against an attempt to “bank” school hours while school was out so two teen actors could keep a heavy shooting schedule. Amazon declined to comment.

Simon declined to be interviewed or to answer specific questions. In a statement he cited an “agenda to discredit the reputation” of his company, then said OLE is “a leader in the field of educating and providing welfare for minors who work in the entertainment industry” and that its mission is academic well-being, safety, and “a commitment to thoroughly understanding and upholding the laws and regulations concerning minors in entertainment.”

The company’s posture toward the people on its list showed up in another forum in 2015, when New York Attorney General Eric Schneiderman’s office reached a settlement with OLE. Investigators found the company had, since at least 2006, required teachers to waive the right to file for unemployment. OLE agreed to drop an arbitration claim for over $30,000 against a New York City teacher who had filed, and to strip those waiver clauses from its contracts. The company declined comment at the time.

What Happens When a Teacher Stops a Shot?

Rachael Dimond, a Georgia-based studio teacher, called the arrangement “a hugely flawed system that is really dangerous.” She has said she was let go from two productions after fights over labor rules for the children in her care.

We are independent contractors. And so we can lose our jobs at the drop of a hat with no reason or excuse given.

Rachael Dimond, studio teacher

The first break she described came in March 2019, on an NBC pilot, where she was teacher and child labor coordinator. An assistant director wanted to keep twin 4-month-old babies on set for an extra hour past the two-hour cap in Georgia labor law and in SAG-AFTRA rules. Dimond asked for written waivers from the Georgia Department of Labor and called OLE for backup. She said an OLE vice president told her she would have to let the production do what it chose, and that she could not stop a freight train by herself.

Waivers arrived 15 minutes before the infants’ allotted time ran out. Hours later, OLE told her she would not come back, even though she had another week of work on the calendar. She also said she was left with unreimbursed hotel bills from the job. The second firing, she said, followed the same shape: she enforced a limit, and the next call did not come.

That is the hidden job description. California’s studio-teacher credential is written as a welfare post with the power to refuse work and remove a child. Off that paper, the adult holding it is a contractor on a list, and the list is owned by a company whose clients are the sets.

Most States Skip the Welfare Worker Job

Federal law does not fill the hole. The Fair Labor Standards Act’s child labor rules do not apply to a child employed as an actor or performer in motion pictures, theater, radio or television. There is no national hour cap, no federal studio teacher, and no federal stop-work badge for a minor on a soundstage. Each state writes its own entertainment rules, or writes none.

California is the strict outlier. For minors under 16, a studio teacher is also a welfare worker who watches health, safety, fatigue and whether the work fits the child’s age. The state’s own regulation says employers shall provide a studio teacher on each call from age 15 days to the 16th birthday, and one studio teacher per 10 minors (or fraction of 10) on a regular call. On Saturdays, Sundays, holidays and school vacations, the ratio for children under 16 loosens to one teacher for every 20. From 16 to 18, a teacher is required when the child still needs schooling that day.

WHO HOLDS THE STOP-WORK POWER

Getting that California badge is not a weekend seminar. A studio teacher needs dual teaching credentials, plus Labor Commissioner studio teacher certification, a written exam on state child-labor rules, and a 12-hour course on the job’s duties. The certificate lasts at most three years and cannot outlive the teaching credentials behind it. Renewal takes a three-hour class on changes in the law. OLE’s own teacher page describes that California post as an advocate for minors on behalf of the Division of Labor Standards Enforcement, and says a studio teacher there may refuse work or remove a child if health, safety or morals are at risk.

Everywhere else, the adult in the school trailer is often just a tutor. A parent or guardian still has to stay within sight and sound in California, for every minor under 18, but a parent who wants the job to finish on time is not a substitute for a welfare worker who can kill a setup. Donnelly’s Gettysburg stop depended on a California credential following a California child. Local extras on a Pennsylvania farm did not arrive with that shield, which is why she said they needed permits she never saw.

CALIFORNIA TIME CAPS BY AGE

• 15 days to 6 months: At most 2 hours at the workplace, and no more than 20 minutes of actual work.
• 6 months to 2 years: At most 4 hours on site, and no more than 2 hours of work.
• 2 to 6 years: At most 6 hours on site, and no more than 3 hours of work.
• 6 to 9 years: At most 8 hours on site; on a school day, no more than 4 hours of work plus at least 3 hours of school.
• 9 to 16 years: At most 9 hours on site; on a school day, no more than 5 hours of work plus at least 3 hours of school.
• 16 to 18 years: At most 10 hours on site; on a school day, no more than 6 hours of work plus at least 3 hours of school.

Every bracket also requires a 12-hour break between wrap and the next call. Makeup and hair count as work even when they happen at home with crew in the room. Violating the entertainment child-labor statutes in California is a misdemeanor, with fines up to $10,000 and jail of up to six months, or both. Failure to produce a valid work permit is treated as proof the child is working illegally.

The 1982 Crash Did Not Change Who Pays

The welfare-worker model did not come from a seminar. It came from a night shoot that killed two children.

THE SAFETY CALENDAR AFTER INDIAN DUNES

1. July 23, 1982: At 2:20 a.m. at Indian Dunes in Valencia, Calif., a helicopter on Twilight Zone: The Movie crashes during a village-explosion scene and kills actor Vic Morrow and child actors Myca Dinh Le, 7, and Renee Shin-Yi Chen, 6.
2. 1982: The children had been hired without permits, paid in cash, and put to work after hours near explosives and a helicopter, which California law did not allow. Director John Landis later testified, “We decided to break the law. We decided wrongly to violate the labor code.”
3. 1982: SAG’s on-set schooling rules take hold, and Simon founds On Location Education the same year to staff the new teacher requirement.
4. March 4, 1986: California files the regulation that now requires a studio teacher on calls for minors from 15 days old to age 16.
5. Early July 2024: Donnelly stops the Gettysburg extra scene, 42 years after the crash, still using a California credential the 1982 deaths helped justify.

No on-set welfare worker would have allowed those two children near a helicopter and explosives at 2:20 a.m. Landis and a producer went around the permit office, kept the names off official paperwork, and paid the parents under the table. Casting agents were not told the kids would work that scene. The later criminal case turned on recklessness and on those labor violations. The structural fix that followed was a stronger California teacher-welfare post, not a change in who writes the teacher’s check.

The paycheck is still production money. In California the studio teacher is licensed by the state and paid by the producer. Parent advocates have said for years that the good ones remember the child, and that others remember the invoice. OLE’s national model extends that split into states that never created the welfare job at all: the company supplies a teacher because union contracts want three hours of school, then sells the producer help with permits in the same relationship.

Four Teachers Describe the Same Gap in Georgia

Georgia is where that split shows up on a hit show. Four teachers who worked for OLE on Stranger Things said child actors were not properly supervised on multiple occasions, including extreme scenes that used wires and ropes. Georgia-based teachers also described children in water tanks and in stunts without the watch they said the work required. During the first three seasons, three of those teachers said OLE discouraged them from watching the kids while they were acting. One said the instruction was to stay in the trailer and wait for the children to be brought in to be schooled.

THE RECORD THE TEACHERS PUT ON PAPER

• Fifteen adults: Teachers, coordinators and parents described alleged breaches in at least six named states.
• Nearly two dozen incidents: The claims cover missing permits, hour overruns, stunts and schooling time that was treated as optional.
• Three hours of school: Union rules still require that block when a child works three or more days in a row, which is the product OLE was built to staff.
• One in 10: California’s weekday ratio is the clearest numerical floor in the country, and it does not travel automatically to a Georgia tank or a Pennsylvania extra call.

Later talk around child performers often skips that staffing fight and jumps to a different fix: keep kids off the shot. Dolls, digital doubles and props do not need a studio teacher, a 12-hour turnaround, or a welfare worker who can kill a setup. That workaround leaves the original conflict untouched. The human safeguard is still a contractor on a production-funded list.

Lawmakers did spend 2024 tightening money rules for children in monetized online video, including a California expansion of Coogan-style trusts to some content creators. Those bills do not rewrite who employs the adult standing next to a working actor on a soundstage. Donnelly’s Gettysburg boys did not go into the movie because a California-certified teacher was on the farm and used the stop. On a set where that credential never arrives, or where the teacher has already been told not to leave the trailer, the same extra call can still run.

Frequently Asked Questions

What Is a Coogan Account for a Child Actor?

California’s Coogan Law, named for 1920s star Jackie Coogan, whose parents spent his earnings, requires that 15% of a minor’s gross entertainment pay go into a blocked trust. The parent or guardian must open that account at an insured California institution within seven business days of the contract, and the employer then has 15 business days to deposit the 15%. If the family never produces the trustee statement within 180 days, the employer must send the money to the Entertainment Community Fund, which holds it until the performer can claim it at 18. The 15% set-aside does not apply to a minor working as an extra or background performer.

Why Are Child Actors Exempt From Federal Labor Limits?

The Fair Labor Standards Act says its child labor provisions shall not apply to any child employed as an actor or performer in motion pictures, theatrical productions, or radio and television productions. The carve-out covers performers the audience can see or hear; it does not extend to stand-ins, writers, unseen directors, or technical crew. Because Washington stepped back, hour caps, permits and the studio-teacher welfare job exist only where a state wrote them, which is why a California stop-work badge can vanish at a state line.

What Training Does California Require for Studio Teachers?

Beyond dual teaching credentials, the Labor Commissioner requires a written exam on California child-labor rules for entertainment, a 12-hour course on the studio teacher’s duties, and, at each renewal, a three-hour class on changes in those duties. Certification lasts at most three years and cannot run past the earliest expiration date on the underlying teaching credentials. There is no fee for the state certificate, and studio teachers certified by the Labor Commissioner’s Office are carved out of a separate Child Performer Services permit that applies to many coaches and trainers who work with minors seeking jobs.

Do Child Extras Still Need Work Permits?

In California, a minor still needs an entertainment work permit before being hired, including many extra calls; the Coogan 15% trust is the piece that does not apply to extras. Donnelly treated the two Gettysburg boys as workers under Pennsylvania labor law and asked for permits the production did not have, and people close to that Netflix shoot acknowledged the missing papers even while they disputed her account of muskets and fire. A missing permit is not a paperwork nicety. In California, failure to produce one is treated as proof the child is employed illegally.