Student Placements

Introduction

Student placements are an essential part of many undergraduate programmes and postgraduate research projects, providing students with valuable work experience in their chosen disciplines.

Placements types are very wide-ranging, and may include:

  • periods of study at other institutions (e.g. foreign language students);
  • work in office environments (e.g. government departments, financial or legal services);
  • the industrial sector (e.g. engineering or manufacturing);
  • construction sites;
  • specialist laboratories (e.g. chemical or pharmaceutical);
  • practical work which is part of a professional qualification (medical electives).

Such placements may be undertaken in the UK or overseas. Fieldwork and overseas travel are not covered specifically by this policy, but the University’s policies on fieldwork (S5/07) and overseas travel (S3/07) should be read in conjunction with it.

Health and safety law requires the University; and more specifically any department arranging placements, to ensure, as far as reasonably practicable, that their students are not placed in an environment where they are exposed to significant risks to health and safety.  Additional legal requirements also apply to students under the age of 18 since they are subject to more rigorous risk management measures, specifically under the Management of Health and Safety at Work Regulations.

In all cases, the University owes a Duty of Care to its students while on placement, whether in the UK or abroad.

The risks associated with student placements may relate not only to injury and ill health, but also legal liability, business and reputational risks, where the following undesirable outcomes could arise:

  • Injury or ill health (of the student) resulting from work with the organisation providing the placement
  • Injury or ill health (of the student) during the placement but not arising from work
  • Injury or ill health to others, damage to property or loss of income to a business due to the action of the student during the placement.

June 2015

Definitions

(i) The term placement refers to a period of work experience, which may be paid or unpaid:

  1. which is undertaken as an integral part of the student’s course
  2. where the student is enrolled at another host institution during this period
  3. where there is a transfer of direct student supervision to a third party

(ii) The placement provider is the third party to whom direct supervision is transferred.

(iii) The workplace supervisor is anyone engaged by the provider to supervise or otherwise look after the student during the placement period.

(iv) The placement organiser is any member of departmental staff to whom authority is delegated for authorising placements with providers.

(v) A placement or visiting tutor is an individual employed by, or contracted to, a department who visits students while on placement.

Sector guidance

The Universities and Colleges Employers Association, UCEA, has published guidance for the placement of Higher Education Students, which is aimed at providing a general framework for managing health and safety during placements. It promotes a fully integrated, risk-based approach to the planning, preparation, and approval phases of a placement, as well as for the support of students while on placement.

The benefit of this risk-based approach is that requirements for lower risk placements are minimised and the need for more rigorous risk control and management measures can be established for those with greater risk, for example the requirement for more detailed documentation, or training and support for the student(s).

This policy outlines key elements of the UCEA guidance, but the full document can be seen here:

Health and Safety Guidance for the Placement of Higher Education Students

Personnel in departments who are responsible for organising placements should become familiar with the text in full.

The legal framework

(i) Criminal liability under health and safety legislation

For placements in the UK:     

Primary responsibility for managing the health and safety of a student on placement in the UK resides with placement provider (under Section 2 of the Health and Safety at Work Act (HASWA), 1974) where the student is regarded as one of the provider’s own employees in relation to health and safety.

The student has responsibilities to act sensibly, follow instructions and to take care to protect their own health and safety, as well as that of others who may be affected by their activities (Sections 7 and 8, HASWA).

Implementation of this policy will address the University’s (and the department’s) responsibilities to non-employees (e.g. students) under Section 3 of HASWA, and provide evidence in defence of any potential charges of negligence under UK Corporate Manslaughter or Gross Negligence Manslaughter legislation.

For placements outside the UK:        

In these cases criminal liabilities on each party will be decided by courts in the UK and the country in which the placement takes place.  For placements overseas the implementation of this policy will address criminal liability under Section 3 HASWA (relating to non-employees).

(ii) Civil liabilities

The nature and extent of civil liabilities between the University, the placement provider and the student, and to others, will be influenced by many factors and may only be resolved in the courts, and may depend on which country’s legal system is deemed to have jurisdiction.

Civil liabilities will also be influenced by the nature of agreements between the parties, statements made in advance about what is on offer, assurances that are given, and civil law relating to contracts and services. For example, any statements made by a department about safety checks undertaken on placement providers, which are subsequently found not to have been done, could be considered a breach in the Duty of Care, for which the University could be held liable.

(iii) Business risks

Departments organising placements should consider business risk exposure in terms of adverse financial or reputational risks – not only from a health and safety perspective.  The business risk review should include civil liabilities arising from untested assurances from placement providers, false marketing claims and consider any exclusion from insurance policies.

(iv)  Insurances

Liability insurance

a. The University’s Public Liability Insurance will normally cover both the University and the placement provider for any claims where the University is deemed to be at fault.

b. Since the placement provider is responsible for the health and safety of the student during the placement it must have Employer’s Liability (EL) Insurance to provide cover for their liabilities to the student during this period. Departments should check that UK providers hold EL Insurance. If not, the University’s Insurance Office should be consulted for advice.


c. Overseas placements are more complex. Some countries may require organisations to have EL-type Insurance cover (also known as Workers’ Compensation Insurance), but there are exceptions. When considering possible placements overseas, departments should check with placement providers that the provider’s insurance will cover liability for injury or illness suffered by students which are attributable to their work with the provider. ‘No’ answers should be referred to the University’s Insurance Office.


d. The placement provider’s Public and Employer’s Liability Insurances will normally indemnify students for any injury and / or property damage that they might cause while undertaking work ‘in good faith’ and under the supervision of the provider. However, such insurance will not cover students for the consequences of any deliberate, irresponsible or malicious act.

For UK placements departments should check that providers have equivalent cover in place.

Professional liability insurance

e. Students training for a profession may be held legally liable for professional risks, e.g. medical students. Medical students working within the NHS in the UK are covered under a clinical negligence scheme for the Trusts. However, if the placement is in a private medical facility the placement organiser must ask the provider if their insurance covers liability of the student for injury to third parties, or property damage, arising from their duties. If not, further advice should be obtained from the Insurance Office.

Similarly placement providers overseas must confirm that their insurance will cover liability incurred by the medical student in the course of their duties while on placement.

Driving insurance

f. Students driving a vehicle during a placement will normally require compulsory third party motor insurance, although this may be made available by the placement provider, if the student is required to drive on business. Students who plan to drive their own or a family member’s vehicle for work purposes must check that the insurance policy covers ‘business’ and not merely ’social, domestic and pleasure’ use of the vehicle.

Travel insurance

g. Prompt response to most personal accident, travel and health emergencies can be covered by a suitable travel insurance policy for those students who are placed overseas. Most travel policies will also provide an element of personal liability insurance. However, care must be taken when selecting a travel insurance policy since the extent of protection can vary widely and many policies contain small-print exclusions (e.g. claims arising while under the influence of drugs/alcohol, or from participation in specified ‘dangerous’ activities, or travel to FCO flagged countries). Most standard holiday travel policies are unlikely to be adequate, since they will not cover the student for ‘business’ purposes. Cover for emergency medical support and repatriation is essential for students placed overseas.

The University’s travel insurance policy offers comprehensive cover and students on an approved placement are deemed to be on University ‘business’ and are therefore eligible to apply. It should be noted, however, that this policy will not cover leisure activities.

Conditions of travel insurance cover must be scrutinised carefully to ensure that they meet the needs of the student(s) on placement.

Risk managment approach

Departments must apply the following risk management principles when arranging student placements, both in the UK and overseas:

(i)        Clarity and understanding of roles and responsibilities

(ii)       Risk assessment, approval and review of placements (Section 7 considers the risk assessment process in more detail)

(iii)      Properly functioning systems to enable students to raise and resolve problems prior to, during, and at the end of the placement

(iv)      Contingency planning, with a level of detail that is proportionate to the risks associated with all placement

(v)       Student preparation and provision of information on:

  1. the industry and the placement provider
  2. the location and cultural, or other, aspects which may be relevant to their health and safety
  3. general health and safety training which will allow them to make informed judgements about risk and risk control measures

(vi)      Training for staff arranging student placements.

Roles and responsibilities

Each party involved in the placement should have a clear understanding of their respective roles and responsibilities.  Agreements must be documented, including any limitations on the extent of the work, and formally acknowledged by the department, the placement provider and the student in turn.

Departments must inform the placement provider of any expectations in relation to health and safety and raise any questions to be answered in order to approve the placement. These expectations should be set out in writing as part of the planning phase, and questions should be answered by the provider before commencement. 

Additional expectations regarding codes of conduct or learning outcomes, for example, could also be documented, along with relevant, specific objectives of any party.

Additional roles may also need to be assigned in cases where the risk assessment and placement review has identified additional risk factors.

What factors should be included in the risk assessment?

The risk assessment and review process should consider the placement itself, the placement provider, and the student / student group in terms of the following:

 (i)            Work factors

These relate to the placement provider and the work–related hazards to which the student will be exposed while working. These risks may range from high risk activities (e.g. construction sites, industrial settings, handling toxic chemicals, or work with ionising radiation) to low risk activities (e.g. archival work).

In some cases there may be specific pre-requisites before the work can be undertaken (e.g. bio-science placements may require hepatitis B vaccination for handling human tissues), and this must be arranged in good time.

 (ii)           Travel and transportation factors

Travel and local transport may present risks to the student when travelling to / from the placement and / or the student’s accommodation. In many developing countries a significant risk is road travel, due to poor road conditions, badly maintained vehicles or poor standards of driving. If the placement itself requires driving a further risk may be the lack of experience of the student, generally, or when driving in difficult terrain.

(iii)          Location / regional factors

The location of the placement may represent a risk due to the student’s lack of familiarity with the surroundings, lack of travel experience, or understanding of local culture, and this could apply equally to international students undertaking a placement in the UK.

Further risks to personal safety and security arise if the placement is to take place in an area which is prone to civil unrest or political volatility. The Foreign and Commonwealth Office provides detailed country-specific information which must be consulted when overseas placements are being considered.

https://www.gov.uk/government/organisations/foreign-commonwealth-office

 In general terms placements must be avoided in countries where the FCO advises against travel, except where the required work experience is essential to the student’s studies, and where experience cannot be obtained at an alternative, safer, location. In those exceptional circumstances the full requirements of the University’s overseas travel policy will also apply.

 (iv)         General / environmental health factors

The student may face health, safety and welfare issues associated with environmental conditions; generally, at their placement, in their accommodation or with food and drink.

Where placements are arranged in tropical locations vaccinations and medical prophylaxis, (e.g. malaria protection) may be required. Placement organisers must ensure that students seek medical or health professional advice about such requirements.

The University’s Occupational Health Service can provide expert travel advice.

Further information on country specific health risks may also be found at: https://www.nathnac.org/ds/map_world.aspx

 (v)          Individual student (or student group) factors

The health, knowledge, maturity, skills, experience and personality of each student will vary considerably, and have an impact on their health and safety in specific environments. Students with health, disability, linguistic or cultural needs may require specific adjustments or support, and the relevant department must work closely with placement providers to ensure the adequacy of any access and support to be provided. Consideration should also be given to overseas placements where the student’s gender could lead to vulnerability.

 Students with chronic health issues will need special consideration with respect to their fitness for placements overseas. They should be encouraged to disclose relevant information so that suitable providers can be identified, and a health management framework and support system established.

 (vi)         Insurance limitations

Any insurance limitations or exclusions must be examined critically, to ensure that neither student; placement provider, nor the University is exposed to risk. Insurance issues are covered more fully in section 4(iv).     

UPS S2/15 Appendix 1 (27kb) provides some examples of high, medium and low risk profiles for each factor, along with examples of action that could reasonably be taken to control risks. These examples are not exhaustive.

Initial assessment may flag one or more elements as high risk due to a lack of information. However, once obtained and potential issues are more clearly understood, it may be appropriate to downgrade the risk.

If the risk is judged to be high it does not necessarily mean that the placement should not proceed, but additional planning and preparation will be required and additional assurances sought from the placement provider.

Departments should develop and tailor risk assessments to reflect the types of placement undertaken, and develop groups of placements with similar risk profiles. This will identify where additional preparation may be required, the scope and content of written agreements and the possible requirement for pre-placement visits. It will also provide for consistency in approach for placements with higher risk profiles.

Placement approval and review

If the department is satisfied that roles and responsibilities have been established and that suitable arrangements are in place, the placement may be approved. Feedback from previous students can help inform the process and should be sought to identify any issues of concern, along with a check to see that none remain unresolved.

Final approval for undergraduate placements should be given by the relevant degree programme director, and for postgraduate researchers approval for the placement would be the responsibility of their supervisor.

Note that in those exceptional circumstances where overseas placements are in FCO flagged locations, there is an additional requirement for the Safety Office to review the risk assessment and for the head of department to give final approval for the travel.

UPS S2/15 Appendix 2 (25kb) provides one example of how the approval process might be recorded, along with a health and safety checklist, and summary of the risk assessment. Departments are at liberty to adapt this according to their own needs, or to extract relevant sections for inclusion in their own documentation, where appropriate.

Departments should consider their portfolio of placement providers on an annual basis to identify any against whom health and safety concerns have been raised. If deficiencies are highlighted, written assurances should be obtained confirming that appropriate action has been taken, before further placements are arranged with the provider. If not forthcoming, placements with that provider should cease.

Some departments may place groups of students with the same provider on an ongoing basis, where work activities are broadly similar. The provider’s arrangements may be well established and it would be unnecessarily burdensome to repeat all the checks for every individual concerned.  A more generic assessment for the group would be adequate, as long as no significant issues have been identified for any individual student (in which case a separate risk assessment would be appropriate).

Pre-placement visits

Pre-placement health and safety inspections may be useful, although they are generally only required for placements where specific concerns have been identified, and which can only be adequately answered by a site visit and inspection.  (The University’s policy on overseas travel, S3/07, may also apply to these visits if the placement is abroad).

UPS S2/15 Appendix 3 (24kb) is presented as a general guide for departments when deciding whether or not a pre-placement visit is required and the frequency of any communications.

Departments may arrange for tutors to visit the student during the placement, providing an opportunity to review workplace arrangements and for concerns to be raised. Placement tutors may find UPS S2/15 Appendix 4 (19kb) helpful in recording their findings, and the list of general questions can be supplemented with more specific work-related ones, as required.

Raising and resolving problems

Departments and providers should have processes by which students and placement tutors can raise concerns for them to be resolved in a timely way.

In the first instance issues should be raised with the workplace supervisor or the provider’s health and safety adviser. If not easily resolved the student should discuss them with their departmental placement organiser.

Planning for contingencies

Departments must have contingency plans in place, and the depth of planning and level of detail should reflect the risks identified in a specific placement, particularly overseas.

At the most basic level these plans may include a named departmental contact, and deputy, or email address for the student to use in emergencies.

If placement is undertaken in a higher risk, or more rural location, plans should consider measures for obtaining medical assistance, dealing with serious injury or illness, and assistance with loss of property or money.

Overseas placements must be supported by a suitable travel insurance policy, which will cover emergency medical assistance and repatriation (Section 4(iv)).

Students must provide details of how they can be contacted in an emergency while on placement, and the names of next of kin, if this information is not already known.

It would also be prudent to consider the possibility of the premature return of the student(s) to Oxford due to unforeseen events, to ensure that there will be no adverse impact on either their studies or research (e.g. limitations on available lecture or laboratory space).

Preparation of students

Basic information must be provided to students about risk factors and control measures in place for their safety. This information can be usefully conveyed by providing a copy of the risk assessment, but additional information about the environment in which the student(s) will live, work and socialise should also be made available. It may be beneficial for them to consult other students who have been on similar placements in the past. The level of detail included in briefings will depend on the extent to which the placement is unusual, complex or involves significant risks.

In some circumstances, it will be necessary for students to have attained a basic level of competency, for example in medical practice or in the physical, life science or engineering disciplines. Placement providers must stipulate the basic competencies which are to be met and the department check that the student has attained them. This should be recorded in the placement documentation described in Section 6.

Training of staff

Staff involved in organising and supporting student placements should receive training in relevant University policies and departmental procedures they must follow. The University Safety Office provides a suite of training courses, some of which may also be beneficial, in particular the fieldwork planning and supervision course. Departments should consider the available training, identify specific needs and ensure that placement organisers attend.

Departments should also clarify the role of placement tutors and stipulate the experience required when visiting high hazard work environments.

Departmental action

Many departments who arrange student placements will already have health and safety procedures and processes in place for managing them. These procedures need not be replaced, but they must be reviewed against this policy and the UCEA guidance to ensure that they meet the appropriate standard.

Appendices

  1. UPS S2/15 Appendix 1 (27kb) Student Placements– example of risk profiling and risk control measures

  2. UPS S2/15 Appendix 2 (25kb) Placement Planning Checklist and risk Assessment Summary

  3. UPS S2/15 Appendix 3 (24kb) Pre-placement Visits

  4. UPS S2/15 Appendix 4 (19kb) H&S Review Questions– placement visits