Information on managing risks associated with external student placements and internal work experience
Student Placement Risk Management Policy
Robert Gordon University develops people who are “ready for life”, in part by placing and in part by facilitating and providing opportunities for most students to learn, in a working environment.
It is incumbent upon the University to ensure that such work placements provide a high quality and valuable learning experience for each student. However, it is of vital importance that students are not thereby exposed to high or poorly controlled risks to their health and safety by virtue of their placement. Risk management is therefore viewed as an integral part of the academic quality assurance system and cannot be considered in isolation. This policy and procedure deals with the integration of risk management into the wider management of student placements.
In developing Student Placement Risk Management Procedures The Robert Gordon University will have regard to the following principles:
- Health and safety is an integral part of all employment, including student placement. Placement is an opportunity to engage students in health and safety, thereby enhancing both the learning process and preparedness for employment.
- Provided certain key measures are taken by the placement provider to satisfy RGU of their capability and intent. The placement should be considered safe unless other information or incidents suggest the contrary.
- The responsibility to manage health and safety risks lies with the employer or placement provider. The role of the University is to verify the adequacy of the provider’s controls.
- Effort and resource will be targeted at the major risks and controls identified for each placement, not at general health and safety management.
- The major risks and controls are linked to the course subjects, and their control provides a common purpose amongst the School, the student and the placement provider. The identification of these major risks and verification of the provider’s controls will be done, so far as possible, prior to taking up the placement.
- Methods of identifying major risks and verifying controls will be developed and owned locally to suit each course or School.
- Methods of monitoring each placement required to be thorough enough to capture each of the major risks and controls without being overly intrusive for the provider.
- All staff involved in identifying major risks, evaluating controls, verifying their effectiveness, or monitoring other aspects of health and safety during placements must be aware of the risks to which the students may be exposed. Appropriate training will be provided and must be attended.
- Where a requirement of this policy or associated procedures assigns responsibilities to individuals for identification, verification, monitoring, assessing or requires other such subjective judgement, RGU will indemnify all those acting in good faith on its behalf.
- Intervention by RGU during a placement on the grounds of poor health and safety should be exceptional. This will normally only be considered in the case of failures of agreed controls for the major risks.
Student Placement Risk Management Procedure
This procedure expands on the 10 principles contained in the Student Placement Risk Management Policy. In doing so, it outlines a minimum standard that Schools require to adhere to, without restricting the development of local procedures in line with these principles and best practice solutions.
This procedure applies to the placement of students with employers in the UK. It does not apply to placements abroad, but Schools may find the general principles and methods valuable when placing students abroad. Separate procedures will be developed for overseas placement.
“Placement”, for the purposes of this procedure includes both paid and unpaid placements. It only includes placement where the University has arranged, brokered or otherwise facilitated the placement. It does not include placements arranged wholly by the student him/herself, or non-academic-related vacation work where the University has simply allowed its communications to be used by prospective employers.
For the purposes of this procedure “major risks” are those risks inherent in the type of work, nature of the business or working environment that may cause death, serious injury or serious ill-health if improperly controlled.
Reference to “the School” in these procedures relates to the Head of School* as the manager accountable to the University for the health and safety of his/her staff and students. However, it is envisaged that many of the responsibilities will be delegated to Placement Co-ordinators, Placement Tutors and associated administrative support.
3.1 General Arrangements
This Procedure describes the minimum components necessary to deliver a local Placement Risk Management System in each School. In order to be effective, the method of providing each component should be identified in each School and responsibility assigned or delegated for each.
Once in place, the effectiveness of the local Placement Risk Management System should be monitored internally and reviewed at least annually by each School. Although placement will be an element of the health and safety audit system, audits should not be relied upon as the sole means of monitoring due to length of the audit cycle.
All staff involved in the placement of students in locations or with providers likely to involve the control of major risks must receive a level of training appropriate to their involvement and to the nature of those risks.
The training provided will be delivered on campus to a syllabus designed in consultation between the Occupational Health and Safety Office and the Centre for the Enhancement of Learning and Teaching.
Refresher Training will be offered at least every 3 years.
3.3 Prior to Placement
All placement providers will be required to complete a Student Placement Provider Questionnaire. The links below will provide a pro-forma for a covering letter and the questionnaire.
The questionnaire will require to be repeated annually or sooner if an earlier expiry date has been indicated and it is necessary to satisfy the School of continuous relevant insurance cover.
Major risks for each placement require to be identified by the School on identification of a placement provider.
On identification of one or more major risks the School must require the placement provider to provide a written method of controlling these risks. The evidential requirement should not be prescriptive, and may take the form of a risk assessment, method statement or any other management or working system the placement provider has already developed.
The School requires to assess the controls submitted by the placement provider:
- Where the documentation is of apparently sufficient depth of content, and controls appear to be appropriate to control the risk, this should be accepted.
- Where there are obvious gaps in the documentation provided the School should communicate directly with the placement provider to satisfy itself that the provider will control the major risks.
- Where the School cannot satisfy itself that the placement provider has adequate systems to control the major risks, the placement must not go ahead and an alternative provider should be sought.
The School should agree responsibilities with the placement provider in writing. As far as possible, this should be done with management at the location where the student will be placed. As a minimum, this should cover the following:
- Induction training and recording
- The placement provider’s responsibilities as “employer” for the student’s health and safety
- Where appropriate, control of the major risks
- Where appropriate, agreement that the student will carry out a risk assessment on one or more of the major risks.
The student must be given sufficient information, instruction and, where necessary, training to ensure he/she is aware of any risks likely to be encountered during placement, and in particular the controls necessary to control any major risks identified. Training in carrying out a risk assessment, or revalidating the provider’s risk assessment is also required for placements where major risks have been identified.
3.4 During Placement
The student should submit a record of induction training to the School, which should preferably be carried out during the first week of placement and signed by the provider.
The student must be instructed to communicate with his/her Tutor on any concerns over health and safety immediately they arise.
Where major risks have been identified prior to placement, the student should complete a risk assessment on one or more of these major risks as part of his/he course work.
The foregoing paragraph does not apply to short duration (under 3 months) rolling placements. However, where appropriate the student should be trained in the principles of risk assessment prior to first placement, and encouraged to revalidate the provider’s assessment, particularly should concerns arise.
The risk assessment should be submitted to the Tutor as part of the course work. The risk assessment should then be reviewed by the School, and any concerns should be discussed in the first instance between the student and the Tutor.
Genuine concerns surrounding the breakdown of agreed controls for major risks must be taken up with the provider by the School, and the controls reaffirmed or modified and reinstated.
If at any time during the placement the School is not confident that the provider will control any major risk, the placement should be terminated. Advice should be sought from the Occupational Health and Safety Team prior to taking this action.
3.5 Post Placement
In addition to meetings and regular communication during placement, the student normally meets with his/her Tutor after the placement has ended to discuss all aspects of the placement.
During this meeting, the student must be given the opportunity to give the School feedback on the health and safety aspects of the of the placement.
Should significant concerns be raised during this feedback session, or at any other time, a judgement will need to be made as to whether or not to continue placing students with the provider.
Any discontinuation of placement with a provider for reasons of health and safety should be notified to the Occupational Health and Safety Team.
4.1 Dean of Faculty
Responsible to the Principal for:
- Ensuring that the principles and actions contained in this Policy and Procedure are understood and promoted in all Schools in the Faculty.
4.2 Head of School*
*(Includes Associate Dean and Associate Head of School in Aberdeen Business School)
Responsible to the Dean of Faculty for:
- Ensuring that the requirements of this procedure are met as a minimum in the School.
- Ensuring all actions required under this procedure are delegated or assigned to appropriate staff.
- Keeping the effectiveness of the School Placement Risk Management System under review.
- Ensuring all staff delegated or assigned responsibilities under this procedure are released for and attend appropriate training.
- Ensuring adequate mechanisms exist for communication on risk between the student and the School prior to, during and after placement.
4.3 Placement Co-ordinators & Managers, School Managers & Administrators
- Requesting and processing pre-placement questionnaires and ensuring the information is refreshed as appropriate.
- Identifying major risks with the provider, requesting information on their controls, and assessing and agreeing their suitability. (NB elements of this responsibility may be more suited to a member of academic staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1 and 4.2 above.)
- Entering into a placement contract/ written agreement with the provider per 3.3 above. (NB elements of this responsibility may be more suited to a member of academic staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1.1 and 4.2 above.)
- Ensuring the student is given adequate information, instruction and training prior to placement. (NB elements of this responsibility may be more suited to a member of academic staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1 and 4.2 above.)
- Receiving and checking records of induction training.
4.4 Placement/Academic Tutors and Module Co-ordinators
Responsible to the Head of School* for:
- Identifying major risks with the provider, requesting information on their controls, and assessing and agreeing their suitability. (NB elements of this responsibility may be more suited to a member of administrative staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1.1 and 4.2)
- Entering into a placement contract/ written agreement with the provider. (NB elements of this responsibility may be more suited to a member of administrative staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1.1 and 4.2)
- Ensuring the student is given adequate information, instruction and training prior to placement. (NB elements of this responsibility may be more suited to a member of administrative staff. It is incumbent upon the Head of School* to assign or delegate responsibilities in the most appropriate manner – see 3.1.1 and 4.2)
- Communicating with the student on all aspects of the placement, including health and safety.
- Receiving and evaluating risk assessments for major risks as part of the student’s course work.
- Taking up issues concerning the major risks with the provider.
- Debriefing the student on all aspects of the placement, including health & safety.
- Liaising with the Health and Safety Office on concerns surrounding major risks, and in particular where termination of a placement or discontinuing use of a provider is under consideration.
4.5 HR Manager, Occupational Health & Safety
Responsible to the Executive Group, and the designated Health & Safety Director for:
- Specifying, in conjunction with CELT, the content of suitable and sufficient training for placement staff and Tutors.
- Supporting placement staff where appropriate, and in particular on breakdown of controls for major risks.
- Ensuring the School Placement Risk Management System is included in the University’s audit protocols.
4.6 Head of the Centre for the Enhancement of Learning and Teaching
Responsible to the Executive Group for:
- Ensuring delivery of agreed training for placement staff.
Guidance on Accepting Work Experience Pupils
Every year various Schools and Departments give secondary school pupils the chance to gain valuable work experience by working at the University (usually for a week). This takes place as part of a work experience programme organised by a secondary school. The following frequently asked questions should help you better understand the simple steps to follow to ensure their health and safety.
What is the employee status of work experience pupils?
In terms of health and safety legislation only, the work experience pupil is regarded as an employee of the University for the duration of the placement. Therefore, they are entitled to the same health and safety facilities and protection as all other employees. In addition, the pupil is also covered by our employer’s liability insurance.
Who should I inform that I’m taking on a work experience pupil?
Arrangements are in place via Aberdeen City and Aberdeenshire Councils to aid the management of administrative and risk assessment requirements when accepting a work experience pupil. In cases where a work experience pupil will be hosted from another local authority or has an independently organised placement, the Occupational Health and Environmental Safety (OHES) Office (email@example.com) must be informed a minimum of a week in advance to advise on risk assessment - providing the name of the pupil, which secondary school they are from and the dates and work environment of the placement as soon as these are confirmed.
What information do I have to give the pupil’s secondary school?
The secondary school will normally ask for two pieces of information in addition to contact details for the School or Department offering the placement:
The University’s insurance details
These can be provided to you by the Finance Office.
A risk assessment
No matter how dangerous or safe the pupil's tasks may seem a risk assessment will be required because of their potential vulnerability. The arrangements for conducting risk assessments ahead of work experience vary widely depending on the parent local authority. As described above, Aberdeen City and Aberdeenshire Council have processes with which to jointly undertake risk assessments with the host. Other local authorities may request evidence of a risk assessment from the University and in these instances the Occupational Health and Environmental Safety office should be contacted as per above.
It is important to remember when conducting a risk assessment that work experience pupils will not be as mature or experienced as other staff and may not be competent at recognising hazards or danger. Therefore, they may require closer supervision than other staff, especially if using hazardous equipment.
What does the work experience pupil need to known on their first day?
When the pupil first arrives you should give them a brief induction before they commence work which must cover the following topics:
- Emergency evacuation procedures (including the location of fire exits)
- Accident procedures (including accident/incident reporting and first aid)
- The location of welfare facilities (toilets, canteen, staff room) preferably by means of a short tour
- A description of the tasks they will perform highlighting any risks to health and safety as noted on the risk assessment
- Any other relevant information
Who is responsible for the health and safety of the work experience pupil?
As the pupil has the same legal status in terms of health and safety as any other employee so the normal hierarchy of responsibility and accountability within your School/Department applies. Ultimate responsibility for the safety of every employee, including work experience pupils lies with the Head of School/Department.
Is there anything work experience pupils shouldn’t do?
The purpose of the placement is for the pupil to learn by observation and practice. The risk assessment should identify the controls that need to be put in place before allowing a pupil to undertake activities.
In some circumstances there may be specific regulations precluding the pupil from undertaking certain activities such as the use of power tools. However, a common sense approach to risk management should ensure that the pupil can make the most of the placement.
Specific guidance can be obtained from the OHES Office.
What happens if the work experience pupil has an accident?
The normal internal RGU accident/incident reporting procedure should be followed. The OHES office will forward a copy of the form to the pupil’s secondary school for their information.
If the pupil suffers a serious injury then, in addition to the above, the pupil’s secondary school should be notified immediately so that they can contact the pupil’s parent or guardian.
Further sources of information
Further information can be obtained from the OHES Office.