PLACEMENTS (WITH AND WITHOUT WORK-BASED LEARNING) – RISK ASSESSMENT GUIDANCE AND TOOL 1 Introduction The purpose of this document is to assist in identifying and managing the risks associated with placement and/or work-based learning (wbl) activity that is part of a course. It should be used in the course planning and approval process to inform the processes and procedures that will be put in place to manage placements and wbl. It can also, where appropriate, be used in relation to specific placement/wbl providers that may be proposed by students or being considered as new providers – students could complete the risk assessment themselves. The document incorporates guidance on minimum principles to follow in order to manage the health and safety risks arising out of student placements. It sets out reasonably practicable actions to ensure the University fulfils its statutory and common law duties of care towards students undertaking placements. This document relates to the University Policy on the Management of Work-based and Placement Learning, and the associated Audit Record which is completed and presented for course approval and review. This is a tool that may be used and adapted by Institutes and courses in different ways and for different purposes. A Health and Safety Audit Form for placement providers is appended for incorporation into course procedures where appropriate. Risk management principles provide a framework for the general guidance and control measures that are appropriate for managing the diversity of placements, issues, and risks associated with the broad range of potential placements and potential scenarios. This document is not intended to be comprehensive in covering all such potential risks. The benefits of a risk-based approach are that requirements for lower risk placements are minimised, whilst resources are concentrated on those placements likely to be higher risk. 2 A note on health and safety matters Extent of responsibilities and liabilities Primary responsibility for the health and safety of students whilst on placement is with the placement providers. Students have health and safety responsibilities to take reasonable care for their own health and safety and that of others who may be affected by their actions. Liabilities against the University could arise from: Page 1 of 7 civil liability for injury or ill health to students whilst on placement, including foreseeable risks outside of placement activities civil liability for loss, injury or ill health arising out of the negligent actions of students limited statutory liability for injury or ill health to students whilst on placement, and statutory and civil liabilities arising out the health and safety risks to members of staff during placement visits. Risk management The following aspects are viewed as integral to sensible risk management and ensuring the health and safety of students whilst on placement: review and approval of prospective placements providers accepting the University’s health and safety expectations whilst students are on placement preparation of students ahead of going onto placement processes for raising and resolving any health and safety issues arising during the placement health and safety risks to members of staff when undertaking placement visits are subject to suitable and sufficient assessment, and health and safety as it relates to placements is subject to appropriate levels of review and monitoring. Placement/wbl co-ordinators may wish to consult the UCEA/USHA Health and Safety Guidance for the placement of HE students (2009) which contains more detailed guidance and templates for the assessment and management of health and safety related risks. Where students will be undertaking placement overseas, the guidance provided by the UK Council for International Student Affairs (UKCISA) on issues related to risk assessment of student activity abroad should be consulted. Version reference: 1.1b Document approved by: Academic Board 12th July 2012 Date document comes into effect: immediate Author of the document: Director of Quality and Educational Development Date document is due for review: 2016/17 Revision History Committee - Date 8th November 2013 Change Final para weblinks updated Page 2 of 7 Risk factor Characteristics 1.1 UK Government regulated public provider eg NHS, Schools, Colleges Category Low Guidance in relation to management arrangements Standard documentation/agreements likely with good mutual understanding of obligations. 1 Contractual status of placement provider 1.2 UK or international large Company or Charity working within established jurisdiction under international law Medium/ High Standard documentation/agreements likely with reasonable mutual understanding of obligations. Consider other risk factors. 1.3 Private company or organisation not covered by above Medium/ High Consider need to request further information eg policies on health and safety (see example form appended), equality and diversity etc and/or provide more detailed information about requirements/responsibilities. Consider other risk factors. 2 Provider’s relationship with University 3 Provider’s experience in providing placements 4 Cultural, educational and work context: staff and student welfare/equal opportunities 2.1 Formal partnership or contractual relationship to provide placements Low 2.2 Established partner in providing placements Low 2.3 New partner to providing placements Medium 2.4 No formal relationship with University High Ensure information about requirements/responsibilities received and agreed by provider in writing. 3.1 Established provider with several years of experience of similar type of placement Low Check provider is fully up to date with latest guidance/expectations. 3.2 New or recent provider with experience of providing similar placements with other organisations Medium May be possibility of using shared audit/approval processes or access existing records re placement responsibilities. Ensure UW focused induction and briefing. 3.3 Provider new to programme and to type of placement provision High Mechanism should be put in place to check and approve provider status and, if appropriate, audit placement opportunities for suitability. Expect to provide detailed induction and briefing. 4.1 Fully meets UK legislation with respect to health and safety and equality legislation, including for disabled people. 4.2 Fully meets EU legislation with respect to health and safety and equalities legislation, including for disabled people Low Low/ Medium Ensure written information about requirements/responsibilities provided and discussed. May have different approach/requirements re accessibility and learning differences, so may need specific checks and specifications; need to brief and induct students/provider staff. Page 3 of 7 Check Risk factor Characteristics 4.3 Does not meet UK and EU legislation 5.1 Higher Education level accredited study 5 Activities undertaken within placement 6 Contact within placements with vulnerable clients 7 Students’ preparation for placements 5.2 Work based learning within closely defined job role Category High Low Guidance in relation to management arrangements Request information on health and safety (see example form appended) and consider need for additional content to employer agreement. Ensure all parties (University staff, provider staff and students) are fully briefed and they understand and agree requirements. Ensure details agreed and on record. Medium Ensure details agreed and on record; likely to require provider agreement and additionally check content for risk factors which might raise risk level. 5.3 Work based learning without closely defined job role High Likely to require formal agreement between University, provider and student. 6.1 Vulnerable clients are not involved Low 6.2 Vulnerable clients are involved High 7.1 Preparation is delivered through a prerequisite module Low 7.2 Preparation is through taught sessions not part of credit-rated module 7.3 Students provided with written briefing and/or have access to a web-site/can request assistance Medium High Likely to require formal agreement between University, provider and student, including specific risk assessment. May require formal audit of placement re suitability in terms of quality of learning environment. Students require full briefing on responsibilities. Arrangements for monitoring and formalising participation should be in place. Consider how will evaluate engagement and, if electronic, consider monitoring how often students access information and levels of understanding; ensure rapid response available to contact students. Page 4 of 7 Check Risk factor Characteristics 8.1 No mentors used Category Low 8 Placement mentor arrangements 8.2 Mentors optional Low Consider issues re equivalence of experience of students with/without mentors. Where mentors opt in, consider how they are briefed/trained/ supported, eg access to on-line training/briefing. Medium Mentors will require formal systematic briefing and training relevant to their role. Consider how this is delivered, participation monitored and evaluated. 8.3 Mentor arrangements essential 9.1 Sign off attendance/no attendance or ‘validate’ experience and/or student’s work as their own 9 Placement provider involvement in assessment 10 Feedback from students/staff contacts on previous placements with provider Low Guidance in relation to management arrangements Ensure student experience not compromised by lack of formally identified mentor. Ensure there is clear criteria and understanding of reporting and extenuating circumstances procedures. 9.2 Formative assessment only Medium Assessors will require training and support, probably including examples of good feedback practice as well as knowledge of/standards required with ongoing updates. Consider setting up on-line site. 9.3 Involvement in summative assessment (pass/fail/competence) Medium/ High 9.4 Involvement in summative assessment (graded) High As above with strong emphasis upon pass/fail borderline. If assessors have specific practice expertise (possibly assessor accreditation might be required by a PSRB) in competence judgements, support from University may be less intensive. May require joint moderation of judgements made. Assessors will require training and support in marking and feedback including access to examples of judgement at different marking bands together with ongoing updates. Clarity of criteria particularly important. Consider setting up on-line site. A method to provide feedback on marking practice as well as system to moderate/discuss judgements is good practice. 10.1 Positive feedback with no major issue Low 10.2 Student level of satisfaction of placement aspect or on relevant module lower than (mean) average 10.3 No information/data from evaluation or feedback Medium High AER should identify action to address. Ensure system put in place. Page 5 of 7 Check PLACEMENT PROVIDERS’ HEALTH AND SAFETY AUDIT Organisation Address Telephone/ email Who is your nominated contact for compliance with the requirements of health and safety legislation? Name and Position 1 Health & Safety Policy Section 2 of the Health and Safety at Work etc. Act 1974 requires employers of five or more people to have a written health and safety policy statement. 1.1 Do you have a written Health and Safety policy? 1.2 When was the policy last revised? 2 Yes /No Date: Note, the student should receive a copy, or know where it is always available. Training/Induction 2.1 Do you have a policy regarding health and safety training for people working in your undertaking, including use of vehicles, plant and equipment? Yes /No Yes /No 2.2 Will the student be provided with a full induction on their first day including all necessary health and safety training including fire evacuation and workstation assessment if/where applicable? 3 Employer and Public Liability Insurance Please attach a copy of your current certificate to this form or a confirmation letter from your insurance broker confirming details of which Employer and Public Liability Insurance Policies are in force. (Sample letter template) Will your insurances cover any liability incurred by a placement student as a result of his/her duties as an employee? The indemnity limits expected for such insurance should be, in general, at least £5 million. Page 6 of 7 Yes /No 4 Risk Assessment Risk assessment is a legal requirement for all employers, and if you employ five or more people you must record the significant findings of the assessment. 5 6 4.1 Have you carried out risk assessment of your work practices to identify possible risks whether to your own employees or to others within your undertaking? Yes /No 4.2 Are risk assessments kept under regular review? Yes /No 4.3 Are the results of risk assessment implemented? Yes /No Accidents and Incidents 5.1 Is there a formal procedure for reporting and recording accidents and incidents in accordance with RIDDOR and other legislation? Yes /No 5.2 Have you procedures to be followed in the event of serious and imminent danger to people at work in your undertaking? Yes /No 5.3 Will you report to the University all recorded accidents involving placement students? Yes /No 5.4 Will you report to the University any sickness involving placement students which may be attributable to the work? Yes /No Contact Person 6.1 Will the student be made aware of suitable contact persons within the organisation relating to issues of: a. Health and Safety (as above) b. Equal Opportunities? Yes/No Yes/No The above statements are true to the best of my knowledge and belief. Name: Signed:.................................................................................................................................... Position:...............................................................Date............................................................ Page 7 of 7