Guidance on the Risk Management of Student Placements 1. Introduction 1.1 This guidance sets out the MMU framework for the sensible management of the health, safety and welfare of students on placement; and the risks arising from health and safety liabilities associated with placements. 1.2 The prime purpose of any placement is to provide a learning and development experience for the student. MMU has an Institutional Code of Practice (ICP) for placement and work –based learning. The ICP requires programme teams and departments have appropriate procedures in place to provide placements of high quality that comply with health and safety requirements. Health and safety needs to be an integral, rather than a stand-alone part, of the whole process and experience. This guidance should therefore be read in conjunction with the ICP. 1.3 Following initial agreement ‘in principle’ to the placement, or in parallel to this, the tripartite agreement should be signed by the placement provider. The tripartite agreement is the pivotal document in the placement process and sets out the University’s minimum requirements with regard to the entirety of the placement. At this stage it is important to discuss with the placement provider what the University expects from them both in academic terms and in relation to health and safety. 1.4 A placement is an integral part of the student’s course and MMU has the right to refuse to approve any placement on health and safety grounds. 2. The definition of placement for the purposes of this guidance 2.1 This guidance applies to placements that are a period of university approved work or vocational experience undertaken by an undergraduate or postgraduate student whilst enrolled at the University. This could either be as part of their academic studies, or as a period of work or vocational experience that is organised or managed by the University. The placement may be paid or unpaid and either in the UK or abroad. Examples of placements include industrial placements, sandwich placements, teaching assistantships, summer internships (e.g. organised through the Careers and Employability 1 Service), internal internships (but not internships provided through the MMU Intern Scheme for MMU graduates), and voluntary work. 2.2 This guidance only applies to MMU students. 2.3 There are a few groups for which additional legal requirements apply and where the general approach recommended in this guidance may not be sufficient. These are: Placement of students under the age of 18 since they are subject to more rigorous risk assessment under the Management of Health and Safety at Work Regulations; Placements to which specific contractual or legislative requirements apply, such as the placement of nursing students or teacher training. In these cases you should liaise with the University Health and Safety Manager. 2.4 Programme teams, academic departments or schools may find it helpful to customise this general guidance to make it more applicable to a particular course or programme. If you require assistance to do this you should contact the Health and Safety Manager. 3. MMU risk management approach and process 3.1 The benefits of a taking a risk-based approach are that the requirements for the lower risk placements are minimised, whilst resources are concentrated on those placements likely to be higher risk. The placement risk assessment and review process should start following the ‘in principle’ approval of a placement, in line with the University’s ICP for placement and work-based learning. 3.2 The following six health and safety factors applicable to all placements should be considered in the MMU risk assessment and review process: 1. Work This relates to the activities that will be carried out by the student during the placement, including hazards that the student may be exposed to during the work activities. The level of appropriate named supervision is of particular importance within this section. 2. Travel and transportation 2 Travel can be a risk, this may not just involve travel during/or for the placement activities but in some circumstances it may be important to consider travel to and from the place of work. 3. Location and/or region Location can have a significant bearing on the level of risk, particularly if there is unfamiliarity with the country, the culture (specifically around disability, gender or sexual orientation) or the language. The level of risk will be dependent on the student’s familiarity with a foreign country and their knowledge of the language and culture. This may be as applicable to an overseas student being placed in a UK organisation as a UK student being placed in an overseas organisation. 4. General/environmental health This section is concerned with the environmental conditions, accommodation and food/drink. These could include extremes of temperature, endemic illnesses for which prophylactic treatment is required and access to drinking water. It may also be important to consider availability of medication or specific dietary requirements for individual students. 5. Individual student Each student will have different needs due to their health (including mental health), knowledge, skills and experience. In some cases this may require specific adjustments to ensure the student has an equitable experience on placement to other students. 6. Insurance limitations Placements at MMU Students undertaking work experience or placements at MMU will be covered by MMU’s Public Liability or Employers Liability Insurance, depending on the type of placement. MMU staff members hosting the student have a duty of care to make sure: The student is supervised adequately A risk assessment has been filled out for the placement/work experience student’s activities. Induction, safety and security is managed effectively and risk is reduced. If the student’s organisation requires proof of insurance from MMU please contact the Insurance Officer on insurance1@mmu.ac.uk 3 Placements within in the UK but external to MMU Other organisations providing placements for MMU students in other the UK (England, Scotland, Wales and Northern Ireland excluding the Isle of Man and the Channel Islands) need to have their own insurance cover in place as the student will be classed as an employee during the time that he/she is on placement. This means confirmation that the student is covered under the placement organisations employers’ liability policy and a copy of their insurance certificate should be requested: Employers’ liability insurance – (£5m minimum and compulsory for companies in the UK under the Employers’ Liability (Compulsory Insurance) Act 1969). Placements Abroad (Outside the UK) There are three insurance areas that need addressing before a student goes abroad on a placement. a) Personal Accident and Personal Possessions b) Personal liability and personal accident and injury whilst undertaking placement activities. c) Placements over 365 days The full guidance relating to these three insurance areas is set out in Appendix 1 Students under the age of 16 on placement or completing work experience at MMU University staff, the student and the student’s organisation must be aware that the insurers require the student to be constantly supervised whilst on placement with MMU. If a student is under 16 and has been accepted on a MMU placement the Insurance Officer must be sent email notification as soon as possible containing the following information: I. II. III. IV. V. Name of student Dates the student will be on placement (inclusive) Activities the student will undertaking with a risk assessment The name of the primary staff member(s) responsible for supervising the student, and confirmation from the Head of School/Dean of Faculty they are aware and are happy for the placement to go ahead. 4 Clinical Negligence of Students within the UK In the UK, MMU’s Public Liability insurance provides contingent cover for the clinical negligence of students whilst working under the guidance of a qualified professional. It does not provide cover for the qualified professional and therefore they must maintain their own professional indemnity cover, along with the requisite liability covers. As a licensed professional they should also have their own medical malpractice cover (depending on the nature of their work). 4. Completing the risk management process 4.1 In carrying out a risk assessment consideration should be given to each of the six factors set out in section 3 of this guide, in order to make an informed decision whether the risks associated with the placement are acceptable. 4.2 The risk assessment process: Step 1– Assess the risks A health and safety risk assessment should be carried out using the Placement Risk Management Action Plan Guide and form (Appendices 2 and 3). The Guide to Risk Profiling document (Appendix 4) should be referred to in order to help identify risks and possible actions to reduce the risk . The assessment should consider the risks described in paragraph 3.2. Each factor should be given a rating of high, medium or low risk. Using the plan enables you to collate relevant information in one key document; it also helps identify areas to consider relating to risks associated with the placement and apply a level of risk using the ‘Guide to Risk Profiling’ document. The action plan form can be adapted and departments, schools and Services can add specific local additions. Once completed the plan is a record of the actions required and who is going to carry them out e.g. the student, the placement provider or the University. Once all the actions in the action plan have been completed, the academic tutor needs to decide if the level of risk is at an acceptable level. If not all identified actions have been completed, or if the academic tutor does not think that the level of risk is acceptable, then you should discuss the placement 5 with the Health and Safety manager/Advisor and Head of Department or School. If, at this point, you deem the risks too high then you will need to take the advice of your Dean and decide whether to escalate a final approval decision to Secretariat. Step 2 - Approval and Sign-off of the Placement Risk Management Action Plan Once completed, the action plan should be signed off by the Head of School or their delegated nominee. The action plan should be kept along with the tripartite agreement and any other key information relating to the placement (e.g. information on insurance, risk assessments from the placement provider and information on the activities to be undertaken). Copies of the action plan should be retained within the School, and shared with the student and placement provider. Step 3 – Preparation for commencement of the placement Pre-placement visit The academic tutor, having considered the level of risk associated with the placement, should decide whether to make a pre-placement visit or to carry out a visit during the placement. Where possible and having considered the risk placement providers can carry out assessments. It should be noted that a visit could be combined with one that is carried out as a requirement of the Institutional Code of Practice for Placement and Work-Based Learning. A pre-placement visit would only be necessary where the placement offers a very high risk or where there are significant concerns that would be easier to resolve through a visit. A visit would look at the suitability of the placement from the levels of supervision that are going to be available to the student; what the student is going to be doing and the level of control measures in place for these activities. Determine the process for raising concerns during the placement A process for students or the placement provider to be able to raise concerns should be developed locally in conjunction with the Health and Safety Manager; this should cover academic concerns, minor concerns about health and safety or other personal issues that the University maybe help to resolve. 6 In the event that concerns cannot be resolved within the School/Faculty or Service or in an emergency, there should be a procedure for escalating the concern and in extreme cases this should feed into the University’s Emergency Management Plan. Student briefing Prior to a placement commencing you should arrange for the student to be given a full briefing which, in addition to academic specific information should include at least: Information specific to their placement - for example copies of the Tripartite Agreement, any other contractual placement paperwork and in some cases information from the placement provider. General health and safety issues - the complexity and level of information will depend on the placement, where the placement is to be held and the outcomes of the risk profiling (which you should also include in the briefing). If you need any assistance contact your health and safety manager/advisor. Cultural issues – including personal safety, equality issues such as gender/ sexuality/disabilities and any location-based issues which could include health and travel. What to do in an emergency - Key contacts at both at the placement provider and the University; and the process for raising any concerns – usually the placement coordinator would be the first point of contact. Insurance – covering the key points of what may be needed. The way in which the briefing is delivered should be appropriate to the overall level of risk of the placement. When sending large numbers of students to one placement provider it may be worth organising a briefing with a representative of the placement provider, to ensure all students get the same information. Step 4 – Visits during the placement Visits during the placement would usually be carried out by an academic tutor as they are likely to involve an academic assessment within them; this would also allow the student the opportunity to raise any concerns with regard to health and safety. A visit may also be carried out if a significant concern is raised by the student or placement provider and this cannot be resolved without a visit. N.B. Any visit should only occur following agreement with the placement provider. 7 Step 5 – Feedback and Review Once the placement is over you should gain and collate feedback about both the positive and negative aspects (particularly regarding health and safety) from the student and placement provider which will support future placements to the provider. You should record these with the action plan form. If you need any assistance contact the Health and Safety Manager/advisor. Josie Elson Associate Director, Valuing and Engaging People February 2013 8 Chris Bolam H&S Manager