Health & Safety Pre-Placement Checklist

Safety, Health & Environment Section
FM SHE 012b
Procedural Guidance for the
Management of Health & Safety for Overseas Student Work Placements
March 2018
Version 11.
Document review due: Aug 2019
Please Note: This is a controlled document, please ensure you are using the most recent version.
https://intranet.uclan.ac.uk/ou/fm/Pages/Health-and-Safety-Student-Placements.aspx

Summary

The following guidance document sets out revised University procedural guidance for the management of health and safety for student placements based overseas.

It is centred primarily upon applying new guidance published by the Health & Safety Executive (HSE) entitled ‘Cutting through the bureaucracy’. Though primarily aimed at UK work placements for under 18 years of age the HSE guidance is just as relevant to the over 18’s student age group on overseas placement.

This document is applicable to all overseas student placements arranged by a member of University staff, or by the student themselves, where that placement is part of the student’s course of study or is part of the wider University engagement and learning agenda.

If you are unsure as to whether this guidance is directly applicable to a specific placement please, contact the University’s Safety, Health & Environment (SHE) Section for further advice on (01772 89) 2232.

The health and safety of students on placement is paramount and overrides all other considerations, including academic

Contents Page

1. Introduction 4

1.1 Definitions 4

2. Scope 4

3. Legislative requirements 4

4. Responsibilities 5

4.1 Responsibilities of Heads of School / Service 5

4.2 Responsibilities of the Placement Organiser 5

4.3 Responsibilities of the Placement Provider 5

4.4 Responsibilities of the Placement Student 6

5. Overseas Student Placement Letter of Expectation 6

5.1 Assessing Potential Placements 7

5.2 Overseas Travel & Placement Risk Assessments 8

5.3 Disclosure of Disability 10

5.4 Providing Work Placements for Disabled Students 10

5.5 Disclosure & Barring Service Checks & Safeguarding 10

5.6 Specific Risks and Actions 10

5.7 Approving Placements 11

6. Preparing Students & Student Involvement 12

7. Instruction and Training 12

8. Insurance Requirements 13

9. Training for Placement Organisers 13

10. Communication 13

11. Post Placement Review 13

12. Record Keeping 14

13. Accident & Incident Reporting 14

14. References 14

15. Appendicies 15

1. Overseas Letter of Expectation 17

2. Student Overseas Travel & Placement Information Form, Risk

Assessment Template & Guide to Completion 19

3. Workplace Health & Safety Information for Students on Overseas

Placement 32

1. Introduction

Overseas placements can provide a wealth of both work and leisure time experiences for students that can prove invaluable to their course of study, future employment and personal achievement.

Overseas placements and the associated travel require additional advance planning, care and common sense. It should be noted that travel abroad may expose students to a number of health and safety hazards arising specifically from the travel itself and/or the conditions within the country being visited. These may not be necessarily directly work-related.

Even though health and safety legislation may vary from country to country the fundamental protection of workers tends to be similar, particularly in the EU, North America and Australasia. The University expects that no matter what county the work placement is in, the provider should still provide a safe and healthy working environment.

This revised procedure is intended to realign UCLan’s placement procedures with new Health & Safety Executive (HSE) guidance intended for UK placements whilst still retaining the requirement for students to complete their own travel/placement risk assessment.

1.1 Definitions

·  Overseas – Outside of the UK;

·  Placement - A period of work experience, paid or unpaid;

o  Which is undertaken as an integral part of the student’s course of study; and

o  Where the student is enrolled at the HEI during this period; and

o  Where there is the transfer of direct supervision of the student to the third party.

·  Placement Organiser – A person to whom authority is devolved for organising and authorising the placement of a student.

·  Placement Provider – A third party (usually an employer) who, during the placement has responsibility for the direct supervision of the student.

2. Scope

The following document sets out University procedural guidance for the management of health and safety for student placements based overseas. Separate guidance is available for UK based placements.

It is applicable to all overseas based student placements arranged either by a member of University staff or by the student themselves, where that placement is part of the student’s course of study or is part of the wider University engagement and learning agenda. The exception to this may be placements related to professional practice placements such as nursing, teaching, social work, physiotherapy, etc., where specific contractual arrangements may already be in force.

3. Legislative Requirements

It should be noted that UK legislation does not apply overseas with the exception of the Single Equality Act 2010. The University does however have a common law duty of care for its students while they are overseas on placement.

Under the Equality Act 2010 it is unlawful for a school or other education provider to treat a disabled student unfavorably this includes students on placement. Such treatment could amount to; direct discrimination; indirect discrimination; discrimination arising from a disability; harassment.

4. Responsibilities

There are four main parties to a placement each has specific responsibilities, the Dean of School / Director of Service who delegates placement management to the Placement Organiser, the student and the Placement Provider.

4.1 Responsibilities of Heads of School, Heads / Service

They must ensure that all overseas student placements within their school or service are managed in accordance with this procedure and staff with responsibility for organising and assessing placement providers are allocated sufficient time and resources to complete the task.

4.2 Responsibilities of the Placement Organiser

·  obtain confirmation of the health and safety management arrangements of the host organisation, insurance cover and agreement of arrangements and responsibilities through a Letter of Expectation;

·  ensure the student completes a travel & placement risk assessment for their placement that is ‘suitable and sufficient’;

·  ensure the student does not travel to a country or area against the advice of the Foreign & Commonwealth Office’s (FCO) and/or Red24;

·  assess students ‘fitness’ and general suitability for a specific placement;

·  ensure students are aware of their health and safety responsibilities, to the University, the placement provider, their work colleagues and for their own health, safety & welfare;

·  have active involvement in health and safety issues in respect of the placement;

·  provide reasonable adjustments in supporting disabled students obtaining placement and provide on-going support to students and placement provider during the placement.

4.3 Responsibilities of the Placement Provider

·  ensure, so far as is reasonably practicable, the health, safety & welfare of the student;

·  complete, sign and return the University’s Overseas Student Placement Letter of Expectation (LoE);

·  inform the University of any expected levels of competency the student should have achieved prior to commencement of placement;

·  provide the University with a job description or outline of the expected work activities/duties;

·  appraise the risks that the placement student is exposed too and share any significant findings of the assessment with the student;

·  provide general / specific health and safety information, instruction, training and supervision in respect of the tasks to be undertaken during the placement;

·  meet all statutory health and safety requirements;

·  Informing the University immediately of any unauthorised absence by the student;

·  report accidents and incidents to the Placement Organiser, for monitoring and reporting purposes;

·  ensure disability related adjustments on placement are provided.

4.4 Responsibilities of the Placement Student:

·  if the student arranges their own placement they must provide to their Placement Organiser in good time, all relevant contact details for the provider, a job description and any other information deemed necessary, to allow the placement tutor to assess the providers health and safety management arrangements;

·  their personal contact details whilst overseas for emergency situations

·  not to travel overseas (unless they normally live in that country) or commence placement until the placement is passed by their Placement Organiser;

·  to complete a travel & placement risk assessment;

·  seeking confirmation from their GP that they are fit to travel particularly for ‘long-haul’ flights and have the necessary vaccinations for that country (as required);

·  declaring any relevant pre-existing medical condition or disability that could be potentially worsened by the proposed overseas travel/activity;*

·  same as any other ‘employee’ of the placement provider;

·  to take reasonable care of their own health and safety and that of other people who may be affected by their actions or omissions;

·  to co-operate with the placement provider and Placement Organiser in complying with their legal duties and specifically any requirements highlighted by the risk assessment process;

·  to conduct duties and use equipment as instructed by the placement provider;

·  to inform their Workplace Supervisor of any immediate health and safety risks or shortfalls and their Placement Organiser if they are not resolved;

·  to notify their Placement Organiser of any significant changes to their expected work activities;

·  to inform the University immediately of any unauthorised absence from the placement;

· 

·  to check the country specific safety advice on the UK’s Foreign & Commonwealth Office (FCO) website and RED24 and comply with its requirements;

·  to disclose disability to enable ‘reasonable adjustments’ to be made.*

*Please note: A student is not required to disclose a disability, but non-disclosure may affect the nature and level of adjustment that can be put in place.

5. Student Placement Overseas Letter of Expectation (LoE)

An Overseas Student Placement Letter of Expectation (appendix 1.) completed within the last two years must be in place for all providers prior to any student going on placement.

Placement organisers across UCLan must not send multiple LoE’s for different students going to the same provider, only one LoE is required for each provider. As such the University should consider developing a centrally accessible database of employers who have completed LoE’s.

The Letter is intended to help ensure compliance by detailing the University’s expectations for the management of health and safety by the provider and to clarify roles and responsibilities of the University, the provider and the student. The text of the Letter may be incorporated into existing documentation i.e. a placement learning agreement. The important thing is that providers acknowledge the expectations and responsibilities and return either in hard copy or electronically a signed and dated copy.

If a provider does not agree to the expectations and responsibilities within the LoE, clarification should be sought on the reason why and the issues discussed with the SHE Section as required.

Note: Existing providers should be asked to complete a new overseas LoE every 2 years.

5.1 Assessing Potential Placements

The University must satisfy itself that an employer has adequate risk management arrangements in place to address any significant risks, for lower risk placement activities this process can be achieved through:

·  the reputation / organisers past experience of the provider and whether previous placements have been positive or not;

·  the employers LoE and whether issues of compliance were raised by the provider;

·  the outline of the students expected work activities in relation to the potential degree of risk the placement activities/industry likely involve;

·  general safety standards of the country.

For potentially higher risk placement activities/industry’s more robust checks may be necessary, these may include:

·  taking into consideration the size, reputation and standing of the provider;

·  discussing with the employer what work the student will be doing and what specific controls are in place to manage workplace risks;

·  satisfying yourself that the instruction, training and supervisory arrangements are adequate;

·  specific safety standards within the country.

Potential Risk / Examples
Low - Med / Office based type activities, administration, education, retail, design studios, hospitality, dance, schools, sports coaching IT or other low hazard environments and activities.Security, manual work, sports, printing, wholesale / warehousing, social work, journalism in the ‘field’, etc.
Working in proximity to high risk factors but not directly with them
High / Construction site work, forestry, agricultural, motor vehicle repair;
Metal/wood workshops (operation of machinery with mechanical hazards e.g. high speed rotating parts, crushing, entanglement risks, etc.);
Lab or other work with toxic / hazardous materials.
Community / social work / journalism with known high risk groups/clients e.g. drug abusers, homeless, violent patients.
Work with large or dangerous animals.
Activities requiring specific licenses or qualifications e.g. diving, flying, etc.Placement in any country that includes adventurous activities e.g., those involving an accepted element of risk, challenge or adventure which require specialist competencies such as mountaineering, caving, diving, or trekking in hazardous or remote areas, etc.
Placement activities potentially inflammatory to any countries home government, security forces, military (e.g. undertaking research on minority groups, religious beliefs and political motivation etc.).
Placement travel to remote areas e.g. mountain regions, sparsely populated areas etc., in any county.
Placement in any country which involves a high-risk medical exposure (e.g. work that will involve exposure to persons with disease).
Potential Risk / Examples
Unacceptable Risk / Any placement type in any country or area where the FOC or Red24 advise against travel to.Any activity in the high risk band above where control measures do not meet an acceptable standard.

*Note: although the placement might be in a higher-risk environment, the work the student is doing and the surroundings they are working in may not be, for example a placement with a construction company may be in the head office and not require site work.

5.2 Overseas Travel & Placement Risk Assessments

Students undertaking overseas placements are required to complete an overseas travel & placement information form and risk assessment detailing the risks and controls associated with the travel, work, their living arrangements and leisure activities overseas. Students are required to undertake this to give them an insight and understanding of the risks and health and safety controls required, for safe travel and living in the specified country (see also Section 6. Preparing Students & Student Involvement).