This Code of Practice applies to all student placements other than those arranged with the National Health Service through the Faculty of Education and Health. Well defined separate procedures are in place for placements in these areas.
Placements involve a significant integrated period of work-based learning that is distinctly different from casual work or any other work related to the course of study. For this to work well it is important that all involved - the University, student and employer - work together before, during and after the placement.
Work placement is a valuable part of a student's education. While on a work placement the student carries out a particular job (or range of jobs) more or less as would regular employees at the place of work. Under UK health and safety law the student shall be treated as an employee of the organisation in which they are placed.
The employer should think through the reasons for taking a Placement Student and ensure that the student recruited is appropriate to the post being filled, and will be progressively developed rather than overwhelmed. Students are good value for money but should not be treated as cheap labour; in all respects they should be treated in the same way as other employees, given appraisals, and also disciplinary procedures if appropriate. In all regards the employer should work with the student and university to enable the learning experience to take place in a safe and healthy environment.
There can be no guarantees that individuals in a work environment will not suffer harm. This Code of Practice will raise awareness of the factors that can reduce the probability of an injury or work related ill-health occurring to a student in a workplace environment. By referring to information contained in this document, Placement Officers will be in a position to make informed decisions on health and safety issues relating to the placement.
Definitions
Placement Officer: Any person within the university who organises or co-ordinates student placements which form part of a university course.
Placement Provider: Host employer or organisation providing the placement.
Placement Student: Students seconded to and working under the control of a Placement Provider away from University premises (unless the University is the Placement Provider). Placement Students may be paid by the Placement Provider or may be undertaking the placement on a voluntary basis.
Visiting Tutor: Any member of the University staff who visits a Placement Student at the premises of the Placement Provider during the placement.
Managing Placements
University staff may not possess sufficient information or expertise to make a valid assessment of the Health and Safety risks which may exist or arise during a placement. A University Placement Officer cannot therefore make a direct assessment of Health and Safety risks associated with individual student placements. Along with the general suitability of the Organisation, Placement Providers will be approved by Placement Officers on evidence detailed by the Provider relating to their awareness of and commitment to Health and Safety issues. The relevant Health and Safety Questionnaires either for UK or overseas placements, should be presented to the Provider for completion prior to the placement commencing work.
Placements arranged by the University
Each University Faculty may have different local placement procedures in place, appropriate to the type of placement and Placement Provider. The principles and procedures outlined in this section represent the minimum requirements on University Faculty's arranging placements. Some Faculties may adopt more stringent requirements due to the risks associated with the type of work undertaken at the placement. For example, an annual renewal of Health and Safety approved status for the Placement Provider may be required.
Health and Safety Approved status
The Placement Officer should determine a safety profile of each Placement Provider. On the basis of this profile, each Placement Provider will be deemed either Health and Safety Approved or not Health and Safety Approved. The underlying principle being that the University of Greenwich can demonstrate that consideration for the health and safety of its students is a priority for approved Placement Providers.
A Placement Provider will be deemed Health and Safety approved upon satisfactory completion of the Health and Safety Questionnaire; or the provider is an OfSTED accredited school, or a Business Inovation and Skills (BIS) college.
Note: A single questionnaire may be sufficient to approve several office-based placements offered by a large organisation. By contrast, an office-based placement and a laboratory-based placement offered by a single Placement Provider may require separate approval.
Health and Safety Approved status will be valid for a period of two years before renewal is required provided no adverse feedback is received from Placement Students or Visiting Tutors or there are changes in legislation that affect the placement.
If a Placement Provider consistently fails to complete the questionnaire or if the completed questionnaire gives cause for concern the Placement Officer must contact the Safety Unit for advice. The Safety Unit will then make a judgement of the Health and Safety Approved status of the Placement Provider, based for example, on an analysis of the completed Health and Safety Questionnaire, direct contact with the Placement Provider, or any other investigations necessary to satisfy the University that the Placement Provider has a satisfactory Health and Safety Management System. If the Safety Unit concludes that the Placement Provider should not receive Health and Safety Approved status, the Placement Officer will contact both the Placement Student and the Placement Provider to resolve the issues raised by the Safety Unit or, if the issues cannot be resolved, cancel the placement.
If a Placement Provider has not completed the Health and Safety Questionnaire prior to the start of a placement the student will be required to give the questionnaire to the Placement Provider on day one of the placement and request its completion as part of the induction process. The student or the Placement Provider should then return the completed questionnaire to the Placement Officer.
If the questionnaire is not completed and returned to the Placement Officer within two weeks of the start of the placement, the Placement Student and Placement Provider should be advised in writing by the Placement Officer that the University has concerns over the health and safety aspects of the placement and that failure to complete the questionnaire within a further two weeks may result in the University formally cancelling the placement.
If the health and safety questionnaire is not returned by the specified date the Placement Officer in conjunction with the Health & Safety Unit will undertake a risk assessment of the placement based on the available evidence and determine whether to approve or cancel the placement.
If a placement is cancelled or rejected by the University the student will be informed in writing that it cannot be accepted as a component of the student's course of study. The general principle should be that, wherever possible, the student's progression through their course will not be adversely affected by the cancellation of a placement on health and safety grounds.
Students Placed under the Erasmus Scheme
Where it is proposed that a student will study at an overseas University, or take up work placement under the 'Erasmus' scheme run by the British Council, assurance will be sought from the Placement University or employer. This assurance will be achieved by the Placement Officer sending them a 'Health & Safety Assurance Checklist for Non-UK Student Placements', along with a suitable explanatory letter. The University or employer will be recognised as the Placement Provider under the Erasmus scheme.
Placements arranged by students
Where a student arranges a placement independently of the University, identical standards apply in that only Placement Providers having a robust safety management system are approved. Where appropriate, students arranging their own placement should be given access to a Faculty's list of Health and Safety Approved Placement Providers. If a student arranges a placement with an approved provider the student must inform the Placement Officer of their placement details, no other actions are required.
Where the placement is with a new Provider, Health and Safety Approved status must be gained as detailed above.
Information for Students and Placement Providers
Information for students
Prior to commencement of placements, the Placement Officer will provide Placement Students with appropriate information regarding their responsibilities, the placement process and the point of contact within the Faculty; the document entitled 'Placement Student Guidance', available on the Health & Safety Unit web pages, may be used for this purpose. There should also be a procedure for contacting Placement Students e.g. by e-mail and/or telephone.
Placement Officers must include health and safety issues at student pre-placement briefings. It is important that records of attendance at these briefings are kept and that Placement Students are not permitted to commence a placement unless they have attended a briefing. For certain types of placements where there are particular health and safety issues, further information may also be required. This information can be agreed and developed by Placement Officers in consultation with the Health & Safety Unit.
It is important that information is given to Placement Students about any known health limitations for a placement they are going on. This information should be indicated by the Placement Provider, for example by their answers given to questions on the Health and Safety Questionnaire.
Unresolved safety concerns
If, during a placement, a Placement Student or Visiting Tutor has any concerns regarding health and safety and the working environment, these should be reported immediately to the Placement Provider and Placement Officer. Any concerns should initially be followed up by discussion and negotiation with the Placement Provider with assistance from the Health & Safety Unit if required. Serious and unresolved health and safety concerns may lead, on the advice of the Health & Safety Unit, to Health and Safety Approved status being withdrawn from the Placement Provider and the cancellation of the placement.
Safeguarding concerns
Placement Providers must report any safeguarding concern relating to a placement student to the University. Safeguarding concerns can relate to a student's behaviour or how a student is affected by the behaviour of others, and can be concerns about:
- Children (anyone aged under 18);
- Vulnerable adults (those over 18 who are rendered vulnerable to harm or exploitation due to their personal situation and/or social circumstances);
- Radicalisation (the process by which a person comes to support terrorism and the extremist ideologies associated with terrorist groups). Safeguarding concerns should be reported to the Placement Officer who should report the concern under the University's Safeguarding Policy. The University will work with the Placement Provider to determine the appropriate response to the concern. In emergency situations, Placement Providers should contact the police and then report the concern to the University.
Feedback
All Placement Students should be given the opportunity to provide feedback to the Placement Officer at the end of the placement via an end of placement interview. In particular, Placement Students should have the opportunity to comment on any Health and Safety issues they may have encountered, positive or negative. This information may be used to inform the Placement Provider's Health and Safety Approved status.
Placements where the Placement Provider is the University of Greenwich
Placement Students with the University of Greenwich are considered as employees for the duration of the placement. This means that the same safety controls should be in place for those students, as are in place for University of Greenwich employees.
Responsibilities
Faculty Operating Officers and Director of Offices will:
- appoint a member or members of staff as Placement Officers to source and liaise with appropriate Placement Providers
- ensure that Placement Officers have the appropriate training, time, experience and other resources to carry out their duties
- approve the appointment of Visiting Tutors based on their competence and experience of the type of work being undertaken at the placement
Placement Officers will:
- send the Health and Safety Questionnaire to each Placement Provider requesting its completion before the commencement of the placement
- follow-up any non-completions of the questionnaire
- determine whether the questionnaire has been completed satisfactorily
- make a judgement about which placements are covered by the Placement Provider's approved status
- maintain a record of Placement Providers Health and Safety Approved status
- liaise with the University Health & Safety Unit for advice on any placement health and safety problems highlighted
Tutors will:
- arrange and make regular visits to Placement Providers. Frequency of visits will be related to the risks associated with the placement
- check and observe with the Placement Student and Placement Provider that the required health and safety measures associated with the placement are being maintained
- report any shortcomings in health and safety to the Placement Officer
Placement Students will:
- comply with all health and safety requirements of the University and Placement Provider
- take reasonable care of their own health and safety and that of others who may be affected by their actions
- report any problems concerning health and safety at the placement to the Placement Officer and/or Visiting Tutor as necessary
The University Safety Unit will:
- provide and assist with health and safety advice when requested by the Placement Officer
Placement Providers will:
- ensure that inductions are carried out in a timely manner
- inform the Placement Officer and/or Visiting Tutor of any concerns regarding the Placement Student
- report all recorded accidents involving the Placement Student to the University of Greenwich
- Provide suitable and sufficient training and instruction for the role being undertaken
- Provide appropriate Personal Protective Equipment (PPE) where required
Guidance on managing placements and guidance for placement students accompany this Code of Practice.
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