Student Placements, Work-based Learning and Study Abroad Health and Safety Policy
Introduction
Placements, work-based Learning (WBL) and Study Abroad opportunities are highly valued by students and placement providers for the benefits they offer. In adopting this policy, Loughborough University (LU) recognises that it plays a pivotal role in ensuring that students and host organisations achieve a successful outcome from their shared experience.
It is the policy of LU that all appropriate placements, WBL and study abroad activities are planned, organised and managed to ensure that:
- The student and members of LU staff involved in the activity are not subjected to unacceptable risks to their health, safety and wellbeing
- The student and members of LU staff involved in the activity do not create unacceptable risks for the host organisation or others
Consideration of health and safety (H&S) and wellbeing issues is integral to the process of assuring the suitability of a placement, study abroad or WBL opportunity. Activity arranged without adherence to the requirements of this policy will not be approved by LU.
This policy has been developed following the best practice frameworks of ASET (Good Practice Guide for H&S for Student Placements), the University Safety and Health Association (Guidance on Health and Safety of Placements) and in fulfilment of QAA expectations and core practices where appropriate.
Scope
This policy applies to all placements, Study Abroad for outgoing LU students, and other forms of WBL opportunities which have an association with the University, including activity that is not part of a module and/or assessed or accredited by LU. It sets out the due diligence procedures for risk assessing activities and checking that the placement provider has suitable H&S arrangements in place. The term placement is used throughout this policy to cover Study Abroad and wider WBL activities.
For undergraduate work placements forming part of a programme of study, the policy should be read in conjunction with the University’s Student Placement Charter. The Charter defines what a placement is, and the responsibilities of the main stakeholders in the placements process. The Student Placement Charter is incorporated in the Academic Quality Procedures Handbook published by Academic Registry on the authority of Education and Student Experience Committee and Senate.
The Part I Year in Enterprise scheme follows this H&S process with some minor adjustments to allow for students running their own business during their placement year. Further information is given in Appendix B.
The policy also applies to activity, which is not linked to a programme of study, but for which the University is administering internal or external funding, and for which LU insurance cover is in place, e.g. international volunteering programmes undertaken during a vacation period. In such circumstances, the overseeing professional service is expected to fulfil the role of the School in managing health and safety processes.
More information about the different types of activity and the specific H&S requirements is given in Appendices A and B. It is recognised that there are several areas of guidance which are beyond the scope of H&S, but which are included for completeness as they relate to the management and approval of placements.
The policy does not apply to LU students on field trips which are governed by the Fieldwork Policy, or to incoming exchange students studying at one of Loughborough University’s campuses.
Stakeholders
The main stakeholders in the placements process are:
- Loughborough University
- The placement student
- The placement provider (‘host organisation’)
- Loughborough Students’ Union
The following areas of LU are responsible for the management and support of placements:
Academic Registry
The Placements, Exchanges & Governance Team has oversight of placements, WBL and Study Abroad (exchanges) governance and is responsible for policy, processes and the use of systems to support the management of these activities. The Placements, Exchanges & Governance Team manages external international mobility funding, and oversees health and safety processes for activities which are not part of a student’s programme, but which attract mobility funding.
Contact: exchanges@mailbox.lboro.ac.uk
Careers Network
The Careers Network is responsible for the provision of careers advice, coaching, employability support and the promotion of skills development opportunities to students. This includes the management of and oversight of health and safety processes for University-supported internships, such as the Talent Match programme.
Contact: careers@lboro.ac.uk
Health and Safety Service (HSS)
The role of the HSS is to:
- Audit compliance with this policy
- Carry out training for LU staff
- Report accidents or near miss incidents to Health, Safety and Environment Committee and ensure that the placement provider has reported notifiable accidents to the Health and Safety Executive
- Investigate accidents
- Liaise with LU Insurance Support regarding civil claims arising from incidents or accidents
- Provide advice and support to those who use and apply this policy
Contact: hse@lboro.ac.uk
Insurance Support
Insurance Support is responsible for the provision of information and advice (including claims enquiries) to students, placements staff and host organisations on all aspects of insurance prior to, during and post placement.
Contact: insurance.support@lboro.ac.uk
Schools
Schools are responsible for the academic management of placements, Study Abroad and other WBL activities forming part of a programme of study. It is the role of the School to assist students to source and prepare for such activities, to monitor engagement/completion and to provide support throughout the activity. Unless agreed with the Placements, Exchanges & Governance Team, Schools will be responsible for the health and safety processes detailed in this policy.
Placement Approval Requirements
Due Diligence
Where Schools are considering approving placements at a host organisation with which LU does not have a prior relationship, further due diligence may be appropriate to ensure that risk is managed appropriately.
Guidance and a Due Diligence Tool is available on the Legal Services website.
Placement Ethics
Additional scrutiny should be given to placements which may pose ethical questions. It is expected that placements which may negatively impact equity, diversity and inclusion, or which could lead to concerns about bribery or corruption will not be approved. Consideration must also be given to the ethics of placement activity which:
- Is governed by the Human Tissue Act
- Involves human participants
- Involves animal testing
- Has military applications
This list is not exhaustive. When considering whether to approve a placement, Schools should follow the principles in the University’s Ethical Policy Framework.
Health and Safety processes
The processes for approving a placement, Study Abroad or other WBL activity vary according to the nature of the activity, but there are seven key elements to LU health and safety processes:
- Pre-placement training for students
- Host Organisation Declaration Form (HODF) – UK and international versions
- Student Risk Assessment – standard version and detailed version for international placements in countries with a moderate or high risk rating
- Student Induction Checklist
- Welfare check/Tutor meetings
- Emergency protocol
- Incident reporting
The requirements for each activity type are detailed in Appendix B.
Health and safety documentation and meeting records will be uploaded to the University’s central system for the management of off-campus activity.
Pre-placement training for students
Students must participate in any pre-placement activity mandated by their School, or the Placements, Exchanges & Governance Team. This includes attending an in-person or online health and safety briefing which should sufficiently prepare the student for the environment in which they will be placed and detail duties such as:
- Their health and safety responsibilities
- The health and safety responsibilities of the host organisation
- Assessing and managing risks for activities they will undertake
- Monitoring and providing feedback to the School
- Informing the School immediately if they have any concerns regarding their health and safety whilst on placement
- Informing the School immediately if they are involved in an accident whilst on placement
It is the responsibility of the School to ensure that all students going on placement are effectively prepared, that briefings/information are focused on ‘risk factors’ and as country specific as possible.
Generic H&S training materials are available from the Placements, Exchanges & Governance Team.
If the student does not participate in mandatory pre-placement preparation activities, the placement cannot be approved.
Host Organisation Declaration Form (HODF)
The placement provider must satisfactorily complete and return a Host Organisation Declaration Form (HODF) to the School. The HODF confirms that the placement provider has suitable arrangements for H&S in place, and appropriate insurance to cover the placement student and any visiting LU staff.
If there is more than one student going to the same placement provider in the same academic year, and the roles and circumstances of the students’ placements are the same or very similar, a single HODF per placement provider is acceptable. This should confirm the names of all placement students covered by the form.
Placement providers can submit HODFs in the following ways:
- Via an official LU online form
- Electronically:
- Completed and signed (in handwriting) by the placement provider, scanned, and e-mailed to LU, or
- Completed electronically and e-mailed from an individual (not generic) e-mail account registered at the placement provider
- On paper (by post)
Should the host organisation be unwilling to sign the HODF, the School should contact the organisation to ascertain which aspects of the HODF are considered contentious. Guidance on resolving issues is available from the Placements, Exchanges & Governance Team.
In exceptional circumstances, where a host organisation is unwilling to sign a HODF and the School has exhausted all opportunities to resolve any confusion, it may still be possible to approve the placement, subject to satisfactory confirmation of arrangements for the assurance of the student’s health and safety, and insurance arrangements. Guidance should be sought from the Placements, Exchanges & Governance Team, Insurance Support and the Health and Safety Service as required.
In all other circumstances, where a satisfactory HODF cannot be obtained, the placement cannot be approved.
i) Support for host organisations
Schools must ensure that host organisations understand that the University will continue to offer wellbeing support for placement students and are provided with appropriate contact details should any issues arise. In an emergency situation involving a student outside of office hours, the 24-hour LU Security Team should be contacted: https://www.lboro.ac.uk/services/security/.
If the placement provider requires further support in respect of the arrangements for hosting an LU placement student, Schools should offer information and guidance as appropriate, referring to the Placements, Exchanges and Governance Team if necessary. However, it is noted that any contract of employment or registration for studies is between the host organisation and the student.
ii) Host Organisation requests for additional documentation
If the host organisation produces their own document such as a Convention de Stage (or other tri-partite agreement) or a Non-Disclosure Agreement (NDA), refer to the Student Placement Toolkit. Such agreements may only be signed by Legal Services.
Placements involving research within the NHS may require a Research Passport. Further information about this process is available on the Research and Innovation Office website.
Student Risk Assessment
Students must submit a risk assessment for all placement activity to be undertaken. Any significant hazards and risks associated with the placement must be identified wherever possible by the student, placement provider and the School. Any agreed actions to mitigate identified risks must be followed by all parties.
Students who are undertaking an activity overseas must register for an account with the University’s risk management platform provider to access information on country/region-specific risks associated with their placement location. The risk rating must be included in the student’s risk assessment. Students are also strongly advised to download the risk management provider’s app and monitor this for local updates whilst overseas.
The six key areas of risk to be assessed are:
- Working hours
- Travel and transportation
- Working with hazards (including but not limited to machinery, toxic or hazardous materials, high risk individuals, dangerous animals, working at heights)
- Location and/or regional factors
- General environmental/health factors linked to the placement location (affecting any student – e.g. vaccination requirements)
- Individual student factors (e.g. health, disability, pregnancy, linguistic or cultural factors)
Where no significant risk is identified within a particular area, a risk rating of low (green) will be assigned and no further action is required beyond the student and host organisation continuing to follow existing policies.
If a risk is rated as moderate (amber), further assessment is required to agree mitigations which should be put in place before the placement can be approved. The host organisation should be involved in these discussions where appropriate.
If a risk rating of high (red) is assigned, further assessment is required to agree mitigations which could be put in place to safeguard the student. The host organisation should be involved in these discussions where appropriate. Further guidance should then be sought from the Placements, Exchanges & Governance Team, Insurance Support or Health and Safety Service as necessary before approving the placement.
If the student does not complete and return the risk assessment, or identified risks cannot be mitigated, the placement cannot be approved.
i) Provision for students undertaking placement activity in a home country designated as high risk
Students may wish to return to their home country to undertake placement activity. Where the country has a higher risk rating than would normally be permitted, guidance should be sought from the Placements, Exchanges & Governance Team, Insurance Support and the Health and Safety Service as required.
ii) Change in circumstances
Risk management is an ongoing part of placement activity. Should there be significant changes to the risk profile of the student’s placement, they should promptly inform the School, who will determine whether a further risk assessment needs to be conducted. Examples of changes which should be communicated to the School include a change of placement location, overseas travel forming part of the employment or student abroad, a change in duties resulting in exposure to new hazards, or an overall change to the risk rating of the country due to political instability.
Student Induction Checklist
All students undertaking longer-term work-based activities must submit an induction checklist within 21 days of the placement commencing, or provide the information to the School via a wellbeing check (Teams or telephone). The checklist will ensure that the host organisation has provided a satisfactory induction, ensuring the student understands key health and safety policies and has received, or will receive, appropriate training in advance of working with hazards. Any new risks identified at this stage are subject to a revised risk assessment.
Wellbeing Checks and Tutor Meetings
In accordance with the University’s Policy on Attendance and Engagement for students on taught programmes, all Part I and outgoing exchange students are required to engage with their School for wellbeing checks and Placement Tutor/Exchange Coordinator meetings. The School should ensure there are no health, safety and wellbeing issues affecting the student, or take action to mitigate new risks, and document the meeting in the relevant corporate system.
Emergency Protocol
LU will maintain a protocol to be used in case of an emergency involving a student who is on a placement activity away from the University’s campuses. An emergency is defined as civil unrest, a global pandemic, natural disaster, political instability, terrorism, or where the student is a victim of a serious crime. The protocol will detail the responsibilities of all involved parties, and set out the means for contacting the University in an emergency. The emergency protocol is published at https://www.lboro.ac.uk/study/overseas-exchange/outgoing/before-you-leave/emergency-protocol/.
For overseas placement activity, the LU emergency protocol is supplemented by a 24 hour emergency helpline provided by the University’s Insurers.
Incident Reporting
Where a H&S incident (accident or near miss) occurs involving a student on placement, or a member of LU staff who is visiting the placement student, this should be immediately reported via Loughborough University’s incident reporting system.
Dependent on the severity of the incident, the School should consider whether additional support to manage the response is required from Professional Services including but not limited to the Health and Safety Service, Insurance Support, and Placements, Exchanges & Governance Team.
Any serious injury or fatality involving a student undertaking placement activity must be immediately communicated to the Assistant Registrar (Placements, Exchanges & Governance), referring to the Guidelines for Student Fatalities if necessary, for further investigation and communication as appropriate across the institution.
Insurance
UK-based and overseas placement activities
a) Employer Liability / Public Liability
Work placement providers should provide insurance cover for the public liability of the student (covering damages caused by the student) and personal accident (covering injuries caused to the student) at the student’s placement workplace. In the UK, host organisations can be expected to hold both Employers’ Liability and Public Liability insurances (with some exceptions). However, for overseas placements, each region/country has its own legislation and regulations governing insurance, indemnity and workers’ compensation. The assessment of the host organisation’s insurance provision forms part of the health and safety processes detailed in Section 4.3 of this document.
Where a student is studying overseas on an exchange programme approved by LU, the LU Public Liability policy may, based on the individual merits of the case, provide cover for a loss by a third party caused by any agent of the University (including students) acting on behalf of the University. In the event of a claim from a student, the host organisation and/or the third party, LU is only liable in respect of something that is at the fault of this institution.
Students undertaking the Year in Enterprise may benefit from LU Public Liability cover where working on a start-up under the supervision of LU. However, if the start-up develops into a trading business, the student must have their own insurance cover in place. Further information can be obtained from Insurance Support.
b) Personal liability
Personal liability cover is provided subject to policy terms and conditions. E.g. If the student becomes legally liable to pay damage in respect of accidental bodily injury (which includes death, illness, and disease) to third parties, or accidental loss of/damage to material property.
Overseas placement activity
a) Travel and medical cover
LU has appropriate insurance (e.g. public and personal) cover in place for all approved LU overseas placement and study abroad (student exchange) programmes, undertaken during an official placement year or other Part of study, and other study or work-based learning activity organised by the University.
LU will provide students undertaking approved placement activity overseas with limited travel insurance cover. This should be supplemented by students’ personal policies. Students must familiarise themselves with the key exemptions of the LU policy and should be in possession of a copy of the Travel Cover Summary document before travelling.
All overseas activity must comply with the health and safety procedures outlined in this document and students must not travel against advice from the UK Foreign and Commonwealth Office or Loughborough University’s Risk Management platform provider.
UK residents who are eligible for a Students Global Health Insurance Card (Student GHIC) must have a valid card when travelling to a European Economic Area (EEA) or other country participating in the scheme.
b) Personal possessions
Outside of the inbound and outbound journey to the overseas placement, all personal possessions are the responsibility of the student and not covered by LU insurance.
Further information about insurance cover can be found at https://www.lboro.ac.uk/study/overseas-exchange/outgoing/before-you-leave/insurance/ (student facing) and https://internal.lboro.ac.uk/info/finance/staff/insurance/policy-documents/ (staff access only).
Managing issues during placements (dispute resolution)
Students who are undertaking placement or WBL activity away from the University remain subject to LU disciplinary procedures under Ordinance XVII. Where issues arise for which the host organisation may be at fault, the School should investigate the matter and seek to support the student to resolve the problems with their host organisation. Where issues cannot be resolved and the health and safety or wellbeing of the student is at risk, the School should consider withdrawing their approval of the placement. Examples may include the host organisation failing to provide a safe working environment, requiring the student to work excessive hours without adequate compensation and support, or failing to adhere to University expectations for equity, diversity and inclusion. Whilst noting that individual students may have different experiences at the same provider, serious concerns should be brought to the attention of the Assistant Registrar (Placements, Exchanges & Governance) to review whether it would be appropriate to approve further activity at the organisation in the future.
Consequences of unapproved placements
Where a placement has not been approved for reasons including:
- Failure of the student to provide placement details (e.g. employer name and contact details, location and placement dates)
- Non-completion of the HODF or provision of alternative documentation to meet LU health and safety requirements
- Student non-engagement with health and safety training/other mandatory pre-placement activities
- Non completion or unsatisfactory risk assessment
The student may not be insured by the University until the placement is approved. If the placement has already started, the implication is that any financial risk is now the University’s rather than the insurer’s. In this situation the student and host must be informed that the placement is unapproved, insurance cover via the University is not in place and that until the placement is approved it has no association with Loughborough University. At this point the host and/or student should be provided with a reasonable deadline (up to 21 days) to engage with the process of completing and returning required documents.
Where a placement cannot be approved, a School decision will be required as to whether the student can undertake a Leave of Absence or can continue with their academic programme. Further information is available in the Academic Registry’s operational guidance documentation.
Where students are undertaking Part I placements which are not associated with the University, they will not be eligible for a UK student loan, or in the case of Student visa holders, the continuation of their Student visa sponsorship.