Student Placements: Health and Safety Guidance Contents 1. Purpose... 1 2. Introduction... 1 2.1. Scope... 2 2.2. Exclusions... 2 3. The legal context... 3 3.1. Duties... 3 3.2. Reporting Accidents and Incidents... 3 4. Risk Management... 4 Table 1. Health and Safety Factors for Student Placements... 4 Table 2. Examples of Risk Profiles for Work Placements... 5 5. Student Work Placement Process... 7 Step 1. Assess Risk Profile... 7 Step 2. Preparing the Student... 8 Step 3. Approve the Placement... 9 Step 4. Monitor the placement... 9 Step 5 Review of Placement...10 6. Insurance...10 7. References...11 Form WP1. Health and Safety Information required...12 Form WP2: Student Placement Approval form...13 Form WP3: Induction Checklist Example...17 1. Purpose These guidelines are designed to assist staff to ensure the safety of each student, when on placement (or sometimes referred to as internship) as a part of course requirements. 2. Introduction Student placement is an important part of many Massey University degree programmes and gives students valuable opportunities to develop and learn through work experience. The term placement or internship refers to a period of work experience, paid or unpaid; which is undertaken as an integral part of the student s course; where the student is enrolled at the University during this period; and where there is the transfer of direct supervision of the student to a third party. 1 1 UCEA Health and Safety Guidance for the placement of Higher Education students 1
Health and safety needs to be an integral part, rather than a stand-alone part, of the whole process and experience. While Massey University and the host organisation have responsibility to ensure students are safe while on placement it is an opportunity for students to develop competency in health and safety in the placement experience. Therefore students should be encouraged to be actively involved in the assessment and management of health and safety risk in their placements. 2.1. SCOPE In some cases there are, or may be, additional legal requirements. This guidance can be used as a starting point, but may need to be supplemented in cases such as: Where there are specific contractual or legal pedagogic requirements, for example, nursing or teaching. Where the work placement student is an independent or freelance consultant. In such cases the student is acting in the capacity of a self-employed person and, in doing so, greater responsibilities for health and safety aspects will fall on them. Such responsibilities should be clarified with the student, including: o The ability to secure suitable and sustainable work that meets with the course requirements covering assessed learning outcomes, o The ability of such placements to meet any association or professional body training requirements, o The knowledge and competency factors of the student and the proposed activity, o The personal/professional indemnity and other insurance requirements relating to a self-employed person, o Tax and income requirements, o Ownership of intellectual property and contractual obligations with host company, o Communication and support from tutors. 2.2. EXCLUSIONS Students who are undertaking their course placement with their own existing employer. For such placements, the risk assessment process outlined in this guidance can still be applied, and this in turn will assist in identifying the suitable control measures, briefing and information needed for the student. A student who arranges work or a placement themselves that is not a part of the course requirements is not the responsibility of Massey University. Operational placements undertaken in the Armed Forces are exempt from these guidelines. For fieldwork, where Massey retains responsibility for students who are undertaking practical work in locations that are not under host workplace control, i.e. where there is no transfer of direct supervision of the student to a third party, please refer to the <fieldwork guidance>. 2
3. The legal context 3.1. DUTIES There are three parties to any placement: 1. The host workplace, 2. Massey University, 3. Student. Each party should have a clear understanding of their roles and responsibilities. It is important to have this captured in writing, shared between all three parties, and acknowledged. Massey has a legal duty under the Health and Safety at Work Act 2015 (HWSA) to ensure that students are not harmed during their work placements. (S30, S36 of HWSA) Both Massey and the workplace where the student is placed (host workplace) have duties as a Person in Charge of a Business or Undertaking. (PCBU) Both have a duty to co-operate, coordinate and consult with each other over health and safety issues relating to the student as far as their influence and control allows. The host workplace PCBU, if in New Zealand, will have the main day to day duties towards the student (who will legally be a worker in the host workplace) to ensure that the workplace and activities that the student undertakes are safe. Overseas student placements will operate under the jurisdiction applicable to the country in which the host work place is operating. Massey should still satisfy itself, that its students will be kept safe during the placement, despite the absence of an active duty on the host workplace to cooperate as there is in New Zealand. While Massey University will not have the day to day influence and control over the workplace where the student is being hosted, Massey still has duties towards the student and must take steps to ensure that the host workplace is as safe as is reasonably practicable. The steps that Massey can and must take are outlined in the check list form WP2 below. The student, whether paid or not, has duties as a worker in the host workplace. The student has legal duties to make sure they take care of their own health and safety and their actions or omissions do not harm anyone else. They must also follow reasonable instructions and the policies and procedures of the host workplace. Students working on placement with children in core children s worker roles for example nurses, social workers, youth counsellors and teachers, are required under The Vulnerable Children's Act 2014 to be safety checked by Police. Schools at Massey University may already have an agreement to conduct safety checking of vocational trainees on behalf of host organisations under the Vulnerable Children Act 2014. e.g. Students in nursing are required on entry to complete police check forms. 3.2. REPORTING ACCIDENTS AND INCIDENTS Any accident, injury, illness or near miss that occurs with a student must be reported to the host workplace and Massey University as soon as possible. The Student incident can be reported on Massey Incident reporting system or by their supervisor in MyHR. 3
4. Risk Management There is a wide variety of workplaces that students may be placed both in New Zealand and overseas. Risk management principles provide a framework for the general guidance and control measures that are appropriate for managing the diversity of placements, hazards, issues, and risks associated with the broad range of potential placements and potential scenarios. Key terms are: hazard is the potential to cause harm, risk is the likelihood or uncertainty of harm occurring when exposed to a hazard. The benefits of a risk-based approach are that process requirements for lower risk placements are less, allowing resources to be concentrated on those placements likely to be higher risk. If a work placement risk profile is judged to be high, it does not necessarily follow that the placement should not happen. It may simply mean that extra preparation and consultation is needed with the host workplace. Since a placement is an integral part of the student s course, the University or the student has the right to refuse to approve any placement as explained in the health and safety policy. For further information on Hazard Risk Assessment please visit the Massey Health and Safety Web page. There are five health and safety factors that should be considered in the risk and review process for all placements. The overall Risk Profile for a work placement is assessed at the highest risk factor assigned to the placement across any one of the 5 factors. Examples of low to high risk factors across each area are set out in the example table 1 and 2 below. TABLE 1. HEALTH AND SAFETY FACTORS FOR STUDENT PLACEMENTS Health and Safety Factor Description 1.Workplace and activities undertaken The actual hazards arising from the work place activities, processes, and substances and how these will be effectively managed to reduce risk. 2. Travel and transportation Depending on nature and location of placement there may be significant risks involved when driving or travel while carrying out the business in the host workplace. Risks may also be to and from the placement or to and from accommodation. 3.Location and/or region Could be significant issues if the student is placed overseas or in an unfamiliar area or culture within NZ, or an international student placed in an unfamiliar area of NZ. Check with MFAT Safe travel site for overseas travel. 4.General/environmental health Students may face significant issues with environmental conditions or the general location of the work, their accommodation, their food and drink, exposure to disease, heat, cold, and weather. 5.Individual student Consider each students, skills, abilities, experience, personality, and health and how this may impact on the placement. 4
TABLE 2. EXAMPLES OF RISK PROFILES FOR WORK PLACEMENTS 2 Please note that these are examples to provide guidance. It is expected that overtime Schools or College s, if they haven t already done so, can build a risk profile of work places where their own students are placed. Factors Low risk Medium Risk High Risk Workplace and activities undertaken Travel and Transportation Location and/or region Office work or other low hazard environments and activities. No driving associated with placement. No significant travel, comfortable daily commute. Placements in NZ with no significant local risks. Working in proximity to high risk factors (but not directly with them). Interviews/surveys with community who are not high risk Interviews with drug/alcohol dependents in a public place. Night travel. Long daily commuting requirement. Student required to drive familiar vehicle in reasonable conditions. Higher than normal likelihood of civil disorder, crime or Hazards that have potential to cause permanent injury or fatalities, including: work at height, toxic dusts, moving machinery, electrical systems, confined spaces Working in environments not at atmospheric pressure. Working in laboratories that may have high hazards Operation of machinery with mechanical hazards such as high speed rotating parts, crushing or entanglement risks. Laboratory work with toxic/hazardous materials. Community work with known high risk groups of clients or locations (drug abusers, homeless, violent patients). Work with animal bedding or large or dangerous animals. Activities requiring specific licences or qualifications (e.g. diving, flying aircraft, crewing an aerial device, driving certain class vehicles). Work involving significant hazards in small companies that do not have professional health and safety advice. Student required to drive unfamiliar vehicles/and or others in vehicles. Student required to drive vehicles off road, Significant travel to reach placement, prolonged or on local transport facilities known to be high risk (poor driving, road conditions or vehicle safety standards). Demanding travel during placement. Significant likelihood of civil disorder, crime or similar danger (e.g. placement in war zones, countries listed as a high risk destination by MFAT (Refer to Fieldwork Policy) 2 UCEA Health and Safety Guidance for the placement of Higher Education students Produced in association with USHA and HEOPS 2009 UK 5
General/environmental health No significant environmental health risks, including accommodation, food and water. Individual student The student has no long-term medical conditions or disability likely to cause episodes of illness or require specific support whilst on placement. Student has relevant knowledge, understanding and skills for the type of work. comparable danger. Delays likely in communicating with tutors and others. Placements overseas in areas identified as low risk by the NZ Foreign Affairs Regional/local conditions require some precautionary measures, e.g. optional inoculations against diseases, medical travel kit is a sensible precaution. The student has personal factors (e.g. health, disability, pregnancy, linguistic or cultural) which may require specific adjustments or support during work, or in social interactions at work. Unavoidable lone or remote work working with and in proximity to significant risk factors Medical and rescue services not available quickly or locally. Means of communication likely to be difficult or compromised. Regional/local health risks require mandatory and specific health protection measures e.g. inoculations. Very hot or strenuous working conditions (e.g. manual working outdoors in the sun). Very cold working conditions (e.g. placement in a food cold storage/cook chill or freeze facility). Poor hygiene, areas where diseases easily transported through food and water Dangerous or unsuitable; accommodation. The student has personal factors (e.g. health, disability, linguistic or cultural) which may increase the likelihood of illness or accident during work-related activity even following adjustments. Advice can be obtained from Massey student Teaching and Learning Services. The student has personal factors (e.g. health, disability, pregnancy, linguistic or cultural) which may require specific adjustments or support if living away from home, or makes them susceptible to episodes of illness. The student s knowledge, understanding, and skills are low for the type of work. 6
5. Student Work Placement Process The process for placement is guidance and should be used in context and connected into other policies and procedures on student placements within Massey and within your College. Undertaking these steps will allow placement staff organisers to: have confidence that managing the health and safety of each student placement to the extent expected by NZ law, provide an objective basis to determine if a placement should be declined on health and safety grounds. The process for a work placement can be divided as follows: Before the Placement: Step 1. Risk assessment of the host workplace and determine control measures are acceptable Step 2. Prepare the student Step 3. Approve the placement During the placement Step 4. Monitor the placement and deal with any health and safety issues that may arise. After the Placement Step 5: Review the placement. The flow chart below and forms WP1, WP2, and WP3 are designed to help you through the process. Student Placement Process August 2016 Step 1. Assess risk profile of proposed workplace against risk factors low risk work place Written Risk hazard Control plans not required Step 2. Prepare the Student Step 3. Approve the placement Complete Form WP2 Placement Approval Step 4. Monitor the placement Step 5. Review the Placement medium to high risk workplace Obtain Health and Safety plans from host workplace Form WP 1 to host Assess H & S risk Controls visit workplace if required Step 1. Assess Risk Profile Based on knowledge of the host workplace, and the tasks the student is likely to carry out make a judgement on the risk profile of the host workplace using the table 1 and 2 above for each of the five risk factors. To make a risk assessment involve people with relevant knowledge about the health and safety issues associated with activities the student may be involved. Contact the health and safety advisor if you need assistance with classifying the risk. If all the risk factors are low then there is no specific measures necessary. The work placement can be signed off for the student without the requirement for obtaining a risk hazard control plan from the host workplace. 7
If the placement provider has been used before and reviewed for health and safety and there are no remaining health and safety concerns then further documentation may not be required. For high and medium risk profiles obtain risk and hazard control plans from the host workplace. Assess that the host workplace has: effective hazard management controls in place, (As per HAWSA Act and Regulations hierarchy of controls), training and supervision, the student can meet expected competencies. Ensure that you have planned for contingencies and emergencies. Make sure the student has a Massey contact 24 hour contact number (for overseas placements) and you have contact details for the student. If the host work place needs assistance identifying and controlling hazards, guidance and samples of risk/hazard registers and controls can be found on the Massey Health and Safety Website. Once you have identified the risk you do need to consider location of the placement, particularly it if it is overseas and if the student can be insured. Step 2. Preparing the Student The student should be briefed on general health and safety in relation to their course and any specific risks associated with the placement. Staff and the host workplace provider can help by providing general information about the placement, and information on the five health and safety factors listed on previous pages to the student before the student accepts a placement. The student should be encouraged to seek out further information and to consider the risks associated not only with the placement provider but with the environment in which they will live and socialise (if applicable). Ensure that the skills and abilities of the student will match the work they are going to be doing. Discuss any personal factors (e.g. health, disability, linguistic or cultural) which may increase the risk of illness or accident during work-related activity and make adjustments to the placement where necessary. Ensure you obtain emergency contact information for the student. Ensure environmental dangers are considered and strategies for different types of crises are developed. Any personal or health information collected from the student should only be relevant to ensure health and safety during the placement. Any information collected, stored and disclosed to the placement host needs their consent; however required disclosure of necessary personal factors will be a condition of placement approval. Personal factor details should be destroyed after the conclusion and review of the placement. Massey University must at all times comply with the obligations of the Privacy Act 1993 and the Health Information Privacy Code 1994, with regard to the collection, use and storage of the information. Refer to Massey University Privacy Policy and procedures or contact the risk office if you need further assistance. If any students require health monitoring as required under the Health and Safety at Work Act 2015 at the host workplace, then the host has the duty to keep these files as per the Health and Safety at Work (General Risk and Workplace Management) Regulations 2016. Massey may ask for results from health monitoring if the student gives written consent. 8
The student should undergo an induction once they arrive at any workplace including those with a low risk profile. An example of induction form WP 3 can be taken to the workplace by the student if the host workplace does not have an induction process. Process for raising problems: Once on placement the student should be encouraged to raise matters first with their host workplace supervisor or the host workplace health and safety contact. If concerns aren t addressed the Student must advise the Massey Organiser who will support the student to resolve any issues. (This includes workplace bullying that students on placement can experience) The student should also be advised on how and who they report all accidents and incidents. Massey staff must report all accidents and incidents that occur to students when on placement to the health and safety office. Step 3. Approve the Placement At this time, you should also review any information and past feedback your department/school may have had regarding that placement provider. If your students have previously been placed there, check to see that there were no health and safety concerns that remain unresolved. When you are satisfied that the provider understands and accepts their roles and responsibilities, there are no unresolved concerns, and all the necessary actions have been completed, you are ready to approve the placement. All this information can be summarised in Form WP2 which you can use as the basis of your records for each student or student. All Work Placements require sign off from the supervising teaching staff or the person in your School who has been authorised to sign off student placements. It is highly recommended that high risk profile work placements have the documentation peer reviewed and signed-off. High risk placements must also be signed off by the Head of School, unless such placement is located in a country listed as a high risk destination by MFAT in which case approval from the college s PVC will be required. All travel must be booked through Massey University preferred provider and follow the Massey Travel Policy and Procedures and Procedures for Course related student travel overseas. Note that any overseas travel requires PVC sign off however travel to any country listed as a high risk destination must also be approved by the VC and Director of Risk and Assurance be notified. Student placements in locations identified on the MFAT Safe Travel website as being extreme risk will not be approved, unless student is already resident in extreme risk country. Step 4. Monitor the placement When the student is out on placement, day to day responsibility for looking after their health and safety rests with the placement provider and the student. Placement tutors, usually for academic assessment reasons, may visit the student at the placement provider s premises. These visits can also be used as one of the processes for assessing whether there are any health and safety issues. Placement tutors should be aware of their surroundings during these visits and raise any matters of concern that they observe with the placement provider. The level of expertise with regard to health and safety that may be expected of a placement tutor will vary depending on their 9
experience, training and discipline. For example, subject-based experience is important for industrial and veterinary placements. If there are no formal visits, then arrange for a check in with the student to see how the placement is going and if they have any concerns. Set up arrangements to monitor changing levels of environmental risk, particularly in overseas placements. Suggested health and safety questions for tutors to ask students are given in form WP form 2. Step 5. Review of Placement The review process is very important and should include collection of feedback from students who have been out on placement, (and where relevant from visiting tutors) on health and safety issues experienced during the placement and their resolution. Examples of questions to ask in a feedback session are on WP Form 2. This feedback will provide evidence that can be used to inform the annual review of the suitability of the placement provider. 6. Insurance Working in NZ Massey University has General Liability Insurance which provides cover against third party property damage and personal injury. It covers students under the direction and control of Massey who are on student placement required as part of their courses, both in NZ and overseas. In NZ it would also be expected for the placement host to have general liability insurance in place. If you have an accident at work then ACC covers workplace injuries to NZ citizens. Overseas students or nonresident citizens are also covered with some restrictions. For further information visit the health and safety web page. If students are driving a motor vehicles ensure that the host workplace has cover for the student. Working overseas Insurance for students ordinarily resident in NZ In overseas placement students will need working overseas insurance as basic travel insurance will not cover students when working. Massey Business travel insurance covers accidents overseas to staff who are working. Cover can be obtained by either: Massey University s Travel Company Orbit when booking travel, or Students arrange their own working insurance, All policies not taken out via Massey should be checked by the Massey Procurement Office to confirm whether they provide adequate coverage. This needs to include adequate evacuation cover, whether medical or environmental related. If you are injured overseas ACC may be able to help you if you return home with an injury that happened while you were overseas. The ACC cover applies whether you have been travelling on business, or on leave or for personal reasons. To qualify, for ACC cover you must be an ordinarily resident in New Zealand at the date of the injury. ACC does not cover illnesses, whether originating in NZ or overseas. 10
You will still need working overseas insurance because ACC doesn t cover you for illness or things such as overseas treatment costs, disrupted travel plans, third party liability, and statutory processes in the country you are visiting, assisted travel or emergency travel. There may be some locations where insurance cannot be obtained. Students are not to be placed in such locations. If in doubt about any cover for students check with the Massey Procurement Office. 7. References UCEA Health and Safety Guidance for the placement of Higher Education students Produced in association with USHA and HEOPS 2009 UK ASET Good practice Guide for health and safety for Student placements Uk.2010 Health and Safety at Work Act 2015 Health and Safety Guidelines for the On Hire Industry NZ 2003 11
Form WP1. Health and Safety Information required. (Optional, send to Host Workplace) Thank you for agreeing to host a student at your workplace. To meet both our health and safety obligations towards the safety of the student, please send the following information to us by (Date) Please feel free to contact the Staff Contact below if you have any questions. Section A. Details of Host Workplace Name of Company /Place Contact Person and Position: Physical Address Email Contact Phone Numbers: Describe Work student will be doing. Hours of Work Address of Accommodation (if applicable) Section B. Details of Massey Staff Contact: Full Name Position and School /College Work Physical Address Email Contact Phone Numbers Section C. Health and Safety Information NOTES Attach hazard/risk register hazards the student may encounter (for medium or high risk workplaces) Is there an accident/incident reporting system in place? Yes No Are there emergency plans in place? Yes No (Attach specific emergency plans for high risk activities) Attach /describe induction details Name and experience of person supervising student Is personal protective equipment needed Yes if yes what no Are particular skills required of the student? (e.g. Drivers licence) Particular attributes needed of person e.g. physically fit, immunity status, inoculation Any other comments Signed by the Host Workplace Representative Name and Signature Position: 12
Form WP2: (Massey Staff Member to Complete) Section A. Details of Host Workplace Name of Company /Place Contact Person and Position: Name of Person Supervising Description of work student undertaking. Start Date Physical Address Email Contact Phone Numbers: Hours of Work Address of Accommodation (if applicable ) Student Placement Approval form. End Date Section B Details of Student /or Student Group Full Name Student ID and Course /School Home Address Email Contact Phone Numbers: Emergency Contact: Name /relationship/ Ph. Number /Address Any Additional Comments Address of Accommodation on placement if applicable. Section C: Details of Massey Staff Contact: Full Name Position and School /College Work Physical Address Email Contact Phone Numbers: 13
Section D. Risk Assessment Have you obtained sufficient information about the type of work and processes to be carried out? Has the host workplace been used before and been reviewed for health and safety? If yes are there any unresolved concerns? Step 1. Assess Risk Profile Risk Profile High, medium or low ACTION NEEDED ACTION NEEDED Completed Work Factor L/ M /H Travel and transportation Factors L/ M /H Locations and or region factors L/ M /H General environmental health factors L/ M/ H Individual student factors L/ M/ H If any element medium to high risk Obtain a hazard/risk plan from host workplace relating to the hazards the student may encounter. Assess the hazard/risk Plans. Is a site safety visit needed? Is there an accident/incident reporting system? All accidents and incidents must be reported to Massey as per procedures. Are there emergency plans in place? Is there a satisfactory induction and training process? Including familiarisation with the operations, facilities, policies, procedures, hazards they may be exposed to. 14
Are the risks tolerable so the placement can be accepted? Step 2. Prepare the Student Discuss and brief student on the risks and control plan associated with the workplace. Discuss with student any personal factors (e.g. health, disability, linguistic or cultural) which may increase the risk of illness or accident. (Seek permission from student before disclosing any relevant personal factors to the host.) Advise students of their legal duties as a worker in the host workplace. Students must take reasonable care of own health and safety; and that any acts or omissions do not adversely affect the health and safety of other persons, comply with any reasonable instructions and policy and procedures from Massey and the host workplace Step 3. Approve The Placement Finalise Risk/Management plans for the student placement. Negotiate and agree any additional requirements you may have with the host workplace. Complete written contract with host. Contract preparation and advice must be sought from the Research and Enterprise Contracts Team. Negotiate any additional requirements and put these in writing. Will the placement be covered by insurance? If no placement cannot go ahead. Are the risks tolerable so the placement can be accepted? Approving Staff Supervising Teaching staff. Name and Signature Date: Peer Reviewer for Medium to High Risk Work Placements Head of School/delegated person/ or SLT (where required) Step 4. Monitor the Placement Follow up questions to ask Students 15
How do you feel about the placement and your own safety and wellbeing? Raise any issues with placement provider contact/manager Did you receive any induction training? What ongoing training have you been given? Have you been left in charge of a situation for which you felt you needed more training or closer supervision? Have you had any accidents or witnessed any accidents, incidents or unsafe practices that you are concerned about? Onsite visits during placement Step 5. Review Placement If yes Notify on Massey/Incident reporting system. Raise any issues with placement provider contact/manager Seek advice from Campus Health and Safety advisor. Address any health and safety concerns noted or raised Have any issues been discussed with host workplace and remedied? Is this workplace suitable for future placements? Documentation to Keep 1. A copy of a Contract as agreed, signed and dated by host workplace and Massey 2. Completed checklists and notes of any workplace visits, or inspections, signed and dated by tutor or person doing a site visit. 3. Completed induction checklists and/or training records or signed and dated by student. 4. Accident/Incident reports and the outcomes of investigations 5. Any notifiable events forwarded to WorkSafeNZ involving student 6. Notes and actions taken to address hazards or concerns raised by the students 16
Form WP3: Induction Checklist Example Student to take to Workplace General : Please complete on Day 1 Location and use of facilities, e.g. common room and toilets Locking and security of premises Communication arrangements (how will you get in touch, what is the supervisor s/mentor s availability for questions, are there any requirements for regular meetings, etc.) Daily routine: Start/Finish times, breaks, lunch, commuting plans Introduce the people that the Intern will be working and interacting with, including Health and Safety representatives (if applicable). Role Induction Explain the task (simplify the task as much as possible, and provide written checklists where necessary); Provide samples or demonstration of outputs expected Explanation and clarification of the responsibilities (including safety), expectations and goals of the position Introduce the work space and equipment Discuss and agree upon expected outputs (including standards and deadlines) Health and Safety Hazards and safety requirements associated with the work ( including training plan on use of machinery/equipment The location of relevant safety information (include safety personnel, policies and procedures if relevant) The location and use of safety equipment (including personal protective equipment) Ensure workstation is set up to optimise comfort if the position involves repetitive work such as use of a computer How to report work related accidents, incidents or illness, access to first aid and rehabilitation (if required) Emergency procedures associated with hazards and place of work (include evacuation plans, assembly points and emergency contacts) Intern Name: Intern Signature: Date: Manager Name: Manager Signature: Date: 17