Safety, Health & Environment Section
FM SHE 012
Procedural Guidance for the
Management of Health & Safety forUK Student Work Placements
July 2017
Version 10.0
Document review due: July 2018
Please Note:This is a controlled document, please ensure you are using the most recent version.

Summary

The following guidance document sets out revisedUniversity procedural guidance for the management of health and safety for student placements based in the UK.

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

This document is applicable to all 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. Introduction4
1.1 Definitions4
2. Scope4
3. Legislative requirements4
4. Responsibilities5

4.1 Responsibilities of Heads of School / Service5

4.2 Responsibilities of the Placement Organiser5

4.3 Responsibilities of the Placement Provider 5

4.4 Responsibilities of the Placement Student6

5.Letter of Expectation6

5.1Assessing Potential Placements7

5.2 Disclosure of Disability8

5.3 Providing Work Placements for Disabled Students8

5.4 Disclosure & Barring Service Checks & Safeguarding9

5.5 Specific Risks and Actions9

5.6 Approving Placements9

6. Preparing Students & Student Involvement10

7. Instruction and Training10

8. Insurance Requirements11

9. Training for Placement Organisers11

10. Communication11

11. Post Placement Review11

12. Record Keeping12

13. Accident & Incident Reporting12

14. References12

15. Appendix13

1.Letter of Expectation14

2. Workplace Health & Safety Information for Students on Placement16

1. Introduction

The University’s former student placement health and safety procedures were based upon national guidance issued to the HE sector by the Universities & Colleges Employers Association (UCEA), Universities Safety & Health Association (USHA) and the Higher Education Occupational Physicians/Practitioners (HEOPS) in 2009.

The Health & Safety Executive (HSE) has subsequently issued new guidance intended to significantly reduce the alleged burdensome process for employers taking students on placement. Though primarily aimed at work placements for under 18 years of age the guidance is just as relevant to the University’s over 18’s student age group.

Entitled ‘Cutting through the bureaucracy’, the guidance makes clear that in the HSE’s opinion many placement management arrangements are overly bureaucratic and go beyond what is required under health and safety legislation. The HSE has made it clear to employers that if the feel they are being over assessed or those placing a student are being overly bureaucratic the employer should report this to them for comment.

This revised procedure is intended to realign UCLan’s placement procedures with the HSE’s guidance and requirements and thus avoid any regulatory intervention, whilst still ensuring students so far as is reasonable practicable are placed in safe environments.

1.1 Definitions

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

  • Which is undertaken as an integral part of the student’s course of study; and
  • Where the student is enrolled at the HEI during this period; and
  • 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 within the UK. Separate guidance is available for overseas placements.

It is applicable to all UK 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 studyor 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

While it should be noted that there is no specific legislation or guidance from the HSE for the placement of over 18 years of age students, the University does have a general duty of care to protect, so far as is reasonably practicable, the health, safety and welfare of its students whileon placement.

The ‘Health and Safety (Training for Employment) Regulations 1990’ in effect lend to students on placement the status of being an employee of the placement provider for the duration of the placement and as such are therefore owed an identical ‘duty of care’ by the employer i.e. the placement provider. Consequently the primary responsibility for meeting statutory health and safety requirements within a placement will lie with the placement provider.

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.

Additional procedural guidance also relevant to student placements:

  • Procedural Guidance for Overseas Placements
  • Risk Assessment for Activities Involving Disabled Staff & Students

4. Responsibilities

There are four main parties to a placementeach has specific responsibilities, the Head 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 student placements involving 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.

4.2Responsibilities of the Placement Organiser

  • to 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;
  • to assess students ‘fitness’ and general suitability for a specific placement;
  • to 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 and welfare;
  • to have active involvement in health and safety issues in respect of the placement;
  • to 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
  • to ensure, so far as is reasonably practicable, the health, safety and welfare of the placement student;
  • to complete, sign and return the University’s Student Placement Letter of Expectation (LoE);
  • informing the University of any expected levels of competency the student should have achieved prior to commencement of placement;
  • providing the University with a job description or outline of the expected work activities/duties;
  • to appraise the risks that the placement student is exposed too and share any significant findings of the assessment with the student;
  • to provide general / specific health and safety information, instruction, training and supervisionin respect of the tasks to be undertaken during the placement;;
  • to meet all statutory health and safety requirements;
  • to report accidents and incidents to the Placement Organiser, for monitoring and reporting purposes;
  • to 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 Organiserin good time, all relevant contact details for the provider and themselves, a job descriptionand any other information deemed necessary, to allow the placement tutor to assess the providershealth and safety management arrangements;
  • not to commence placement until the placement is passed by their Placement Organiser;
  • 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 Supervisorof any immediate health and safety risks or shortfalls and their Placement Organiserif they are not resolved;
  • to notify their Placement Organiser of any significant changes to their expected work activities;
  • 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 Letter of Expectation (LoE)
A 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 LoEevery 2 years.

5.1Assessing Potential Placements

The HSE has stated that there are no health and safety regulations that require the University to carry out workplace assessments for work experience placements, it is the placement provider’sprimary responsibility to ensure the student’s health and safety.

The University however does need to 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 Letter of Expectation 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.

The HSE has stated that for lower risk placements even for under 18’s students a visit to the provider will not be necessary. 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;
  • Potentially visiting the provider and observing management arrangements at first hand.

Potential Placement Risk / Examples
Low - Med / Office based type activities, administration, education, retail, design studios, hospitality, dance, schools, sports coaching ITor other low hazard environments and activities.Security, manual work, sports, printing, wholesale / warehousing, social work with low risk groups, journalism in the ‘field’ covering low risk issues, 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.

*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 Disclosure of Disability, Pre-existing Medical Conditions or Leaning Difficulties

In conjunction with the provider the University has a duty to ensure that if any student has a significant pre-existing health condition or disability it is not worsened by a particular placement activity or the working environment or that the student does not pose a risk to their own or others safety.

Students may feel reticent to reveal a disability for fear of compromising the potential of placement. It is therefore essential that organisers promote positive reasons for encouraging disability disclosure. In certain circumstances there may be a need to disclose to the provider information to allow suitable adjustments to be made, particularly if the use of dangerous chemicals, machinery, work with children etc., is involved.

Students need to be made fully aware that in some cases adjustments cannot be made without prior disclosure being given (although the University has a duty to take reasonable steps to encourage students to disclose a disability, students do have the right to confidentiality).

In discussing with a student whether and what to disclose to a work placement provider, the following issues may be relevant:

  • the need to have appropriate information so that reasonable adjustments can be made;
  • the institution’s and the student’s responsibilities towards staff and clients/visitors at the placement provider;
  • safeguards for ensuring that information will not be used to discriminate against the disabled student;
  • safeguards for ensuring confidentiality of information and details on who will have access to the information;
  • who will make the disclosure – whether this will be undertaken by the institution or by the student.

Please Note: Information on a disability will only be used to inform the risk assessment process and to determine and to perform reasonable adjustment. Not all information about a student’s disability may be relevant to the work placement and should only be passed on a need-to-know basis. “Information which is disclosed in confidence to a member of staff will be kept confidential to that member of staff unless there are risks to health and safety or the University has a statutory duty to release the information” (UCLan Policy Statement on Disclosure of Disabilities).

All information must be kept in accordance with the University’s Data Protection Code of Practice, available at:

If there is any doubt as to the significance of the health effects a particular workplace/activity the placement organiser should seek advice from the SHE Section (ext: 2047).

If there is any concern as to the significance of a student’s pre-existingmedical condition or disabilitythe student should be encouraged to discuss their placement with their GP and/or specialist. In rare cases the student may be asked to provide written evidence from their GP or specialist on their fitness to undertake placement.

5.3 Providing Work Placements for Disabled Students

Under the Equality Act 2010 it is unlawful for a school or other education provider to treat a disabled student unfavorably. Such treatment could amount to:

  • direct discrimination;
  • indirect discrimination;
  • discrimination arising from a disability;
  • harassment.

The Act applies to all the activities institutions undertake wholly or mainly for students, including placements. Disabled students must be offered additional support both in finding work placements and when they are on them.

For detailed information on providing work placements for disabled students see the Department for Education & Skills good practice guide for further and higher education institutions at: This document provides a guide to institutions' duties in regard to work placements and offers practical advice on what institutions can do to ensure quality work placement opportunities for disabled students. It is aimed at institution staff responsible for placements: placement organisers, subject tutors and disability officers/learning support coordinators.

No matter what the placement type or its associated risk,an assessment should be made as to whether the provider requires a pre-placement visit to assess for instance the requirement for reasonable adjustments to be made, access / egress issues, etc.

Further information and advice on disability awareness can be found on the University’s Disability Advisory Service:

5.5 Disclosure & Barring Service ChecksSafeguarding

The Disclosure & Barring Service (DBS)formally known as CRB is part of the Government’s commitment to protect vulnerable people within our society. Disclosure is the process by which individuals can make an application to find out whether they have a criminal record or conviction or other record.

There are a number of potential work situations where students on placement may require to be DBS checked before they start work such as unsupervised teaching, training, instructing, caring, providing personal care, social work with children or vulnerable adults.

Further UCLan guidance on the requirements for DBS checks and process can be found at:

Placement providers are asked to confirmduring the LoE process that students will be fully briefed on the providers safeguarding policies and procedures if applicable.

5.6Specific Risks and Actions

Where significant issues are raised at the assessment processthese must be addressed with the placement provider or clarified with the student and suitable control measures identified. Actions required will be very much dependent upon the issue, the level of risk involved and the cooperation received from the provider and / or the student themselves.