Policy WHS-PRO-028 Student Placement Procedure

WHS-PRO-028 Student Placement Procedure

Intent

James Cook University (JCU) has a responsibility to its students undertaking a student placement to ensure they are provided with a safe work environment. This requirement is in accordance with the requirements of the Work Health and Safety Act 2011 (Qld) (the Act).

This procedure has been developed in order that JCU can satisfy its legal requirements relating to student placements, that the placement process is not bureaucratic but is based on a sensible risk based approach allowing a lighter touch on placements with relatively low risks and a more rigorous control where the risks are higher.

Scope

This procedure applies to JCU students and staff that are involved in placements that are undertaken as part of a JCU course requirement.

This procedure excludes:

student initiated placements that are undertaken solely for the benefit of the student and are not a course requirement;
study exchange at other universities;
field trips. The WHS-PRO-015 Field Trip Procedure should be referenced for field trip activities.

This procedure does not apply to the placement of students by JCU Controlled Entities.

Definitions

Term	Definition
A Person Conducting a Business or Undertaking (PCBU)	A business or an undertaking that is conducted either alone or with others, whether or not for profit or gain. A PCBU can be but is not limited to: a sole trader (for example a self-employed person); a partnership; a company. A Volunteer Association is not a PCBU.
Course Requirement	Placement, which is a requirement of a student’s course of study at JCU. Without successful completion of the placement, the student cannot complete the requirements of their course of study.
Impairment	Impairment in relation to a placement student, means the student has a physical or mental impairment, disability, condition or disorder (including substance abuse or dependence), that detrimentally affects or, is likely to detrimentally affect, the students capacity to undertake activities as part of the placement.
Personal Information	Defined in the JCU Code of Conduct as information about an identified or identifiable individual that is not available in the public domain.
Placement	A period of work, work experience, research or study that is a mandatory or an assessable component of a JCU program or course. A placement may be sourced by JCU or by the JCU student.
Placement Agency	An organisation that, sometimes for a fee, arranges placements for students with Placement Providers. Placement Agencies may include industry bodies or private companies whose sole purpose is to arrange placements (either domestic or international).
Placement Coordinator	This refers to any position or team within a College or Academic Division, which coordinates and oversees the Placement program relevant to a course and/or within a discipline.
Placement Provider	Any individual, facility or organisation that hosts students for placements. This includes but is not limited to any public or private organisation or facility or community based service. A Placement Provider may or may not be a PCBU.
Officer	A person who makes decisions, or participates in making decisions that affect the whole or a substantial part of a business or undertaking or has the capacity to significantly affect the financial standing of the business or undertaking. If a person is responsible only for implementing those decisions, they are not considered an Officer under the Work Health and Safety Act 2011 (Qld). Holders of the following JCU positions are considered Officers: 1. Members of Council; 2. University Executive, Directors and Deans.
Other	Persons whose activities are influenced by the student while undertaking placement.
Reasonably Practicable	Means that which is, or was at a particular time, reasonably able to be done to ensure health and safety, taking into account and weighing up all relevant matters including: the likelihood of the hazard or the risk concerned occurring; the degree of harm that might result from the hazard or the risk; what the person concerned knows, or ought reasonably to know, about the hazard or risk, and ways of eliminating or minimising the risk; the availability and suitability of ways to eliminate or minimise the risk; after assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.
Remote or Isolated Work	Work that is isolated from the assistance of other persons because of location, time or the nature of the work.
Volunteer Association	A group of volunteers working together for one or more community purposes where none of the volunteers, whether alone or jointly with any other volunteers, employs any person to carry out work for the volunteer association.
Worker	A person who carries out work in any capacity for JCU, and includes a student gaining work experience (paid or unpaid).
Workplace	For the purposes of this procedure, a workplace is any place controlled or managed by the Placement Host at which the Student or JCU staff member undertakes activities associated with a placement.

Introduction

The aim of this procedure is to provide Work Health and Safety guidance to the University when undertaking Student Placements. The procedure sets out a risk based approach to determining the reasonable and practical actions the University must undertake to meet duty of care requirements when arranging student placements.

Procedure

1 Duty, Obligations and Responsibilities

1.1 James Cook University

JCU owes a non-transferrable primary duty of care to ensure, so far as Reasonably Practicable, the health and safety of:

students undertaking Placement; and
other persons whose activities are influenced by the student while undertaking Placement.

To fulfil this duty, JCU must eliminate risks to health and safety, so far as is reasonably practicable. If eliminating risk is not reasonably practicable then JCU must minimise those risks so far as is reasonably practicable.

In addition, JCU is to consult, cooperate and coordinate with all Placement Providers and all other duty holders, for example Placement Agencies, as far as is reasonably practicable.

1.2 Placement Coordinator

Placement Coordinators will ensure that:

students are provided with pre-placement information, including, if appropriate, a briefing session, relating to the Placement;
all Personal Information collected from students is treated with sensitivity and confidentiality as per the JCU Code of Conduct, including obtaining the prior written consent of the student before releasing the student’s Personal Information to a third party;
an evaluation of a Placement Hosts health and safety processes for suitability is undertaken prior to each Placement; and
placements are monitored at periodic intervals; and
placements are recorded in the JCU Placement Management system.

1.3 James Cook University Student

Students are not to commence a placement until:

they have completed all pre-placement requirements;
they have been granted approval to enrol in their relevant placement subject;
a student placement agreement or placement schedule (if applicable) has been signed by JCU and the Placement Provider; and
they have received all health and safety pre-placement information.

All students have a responsibility to take reasonable care for the health and safety of themselves and that their acts or omissions do not adversely affect the health and safety of other persons.

1.4 Work Health and Safety Unit

The WHS Unit is responsible for the overall development and implementation of the Health and Safety Management System (HSMS).

As part of the implementation of the HSMS, the WHS Unit has a work health and safety advisory function in relation to placements.

This is done through the:

development and implementation of this placement procedure across the JCU business; and
provision of support, advice, guidance and training to assist the Placement Coordinators and other stakeholders to undertake their duties, obligations and responsibilities outlined in this procedure.

1.5 Placement Provider

The Work Health and Safety (WHS) Act 2011 details the obligations and responsibilities of a Person Conducting a Business or Undertaking (PCBU) to ensure the health and safety of workers and to provide and maintain a workplace without risks to health and safety.

A Placement Provider, if a PCBU, has a non-transferable duty to ensure, so far as is reasonably practicable, the health and safety of students while undertaking placement activities at their workplace.

2. Risk Management Approach

Rather than trying to manage all placements by a common approach which could have an impact on personnel and other resources, it is recommended that a risk based approach to placements be taken.

The benefits of using a risk-based approach are that requirements for lower risk placements are minimised, whilst resources are concentrated on those placements likely to be higher risk.

It is recommended that the following six health and safety factors be utilised to assist in determining the risk profile for placements:

Work Factors

These relate to the placement host and to the work that the student will be carrying out. They include the nature of the work-based hazards to which the student may be exposed. Control measures include professional knowledge and expertise of the student.

Travel and Transportation Factors

Driving and travel when undertaking activities for the placement host could be a risk factor. Depending on the nature and location of the placement, the student may face significant health, safety and welfare issues associated with their travel to and from the placement and to and from their accommodation.

Location and/or Region Factors

The location of the placement can have considerable impact particularly if it is abroad, in a country that the student is not acquainted with, and could apply to international students undertaking placement in Australia.

General/Environmental Health Factors

The student may face significant health, safety and welfare issues associated with the environmental conditions in their place of work or the general location, accommodation, or their food and drink.

Individual Student Factors

Each student is an individual. Their health, knowledge, skills and experience and their personality could have an impact on health and safety in particular environments.

Students with personal factors (e.g. health, disability, linguistic or cultural) which may require specific adjustments or support should have equivalent opportunities in choice of placements. JCU should work with placement host(s) to ensure that access and support requirements will be provided for the student on placement. JCU needs to encourage students with a health condition or disability that may require adjustments or support whilst on placements to disclose this, or to agree for the University to disclose information on this when identifying possible host(s).

Insurance Limitations

Insurance is a means of transferring risk by paying for the provision of professional support and financial compensation if things go wrong. Any assessment must include consideration of the extent and limitations of the insurance arrangements of both the University and the host provider, the contractual arrangement in place and the legal requirements in the country or countries where the placement will take place.

2.1 Risk Profiling Tool

The WHS Unit has developed a Risk Profiling Tool (Appendix A) and a Risk Assessment Template (Appendix B) to help guide business units to profile risk associated with placements. However business units are encouraged to develop and tailor the risk profiling tool(s) to better address issues that could arise from the types of placement that their students may undertake.

The profiling of the placement host(s) can be evaluated against the number scale of the JCU Risk Rating Matrix (refer to Appendix C Risk Level Ratings). At this point a decision can be made on what is reasonably practicable in relation to the duty of care owed by JCU and allocation of resources to assessments with a medium or high risk based on the risk appetite of the University .

An example of a low risk placement might be a standard office-based or business placement.

Some examples of medium risk placements could be industrial, laboratory or nursing placements where there are possibly higher work-related risks, or overseas placements in countries with robust safety legislation and emergency services, such as Europe and North America, but where the travel, location and environmental risks are likely to be greater.

Some examples of high-risk placements could be construction, forestry, agricultural, medical or dental placements where there are possibly even higher work-related risks, or overseas placements in the rest of the world where the travel, location and environmental risks are likely to be even greater. Placements with a high-risk rating will need to evaluate the placement hosts health and safety processes by issuing the placement host with a checklist. The WHS Unit has developed a Student Placement Health and Safety Proforma (Appendix D) however, business units are encouraged to tailor the checklist to their needs.

When producing risk assessments, it is appropriate to involve people with relevant knowledge of the practices and health and safety issues associated with the activities in which a student may be involved. This is particularly relevant in the case of placements with higher risk profiles. For example, in high-risk placements', business units will need to involve health and safety professionals.

3. Incident on Placement

If a WHS incident occurs on placement this must be entered into Riskware once the respective College has responded to the incident. The University’s Incident Management Policy and Procedures may also apply for notification and response actions.

4. Post Placement

Health and safety should be included as part of each post Placement debriefing or evaluation process with students.

This will provide the Placement Coordinator with more information about the health and safety of the different workplaces for future Placements if applicable.

The Placement Coordinator should record any work health and safety concerns for future engagement with the Placement Host.