WHS-PRO-028 Work Integrated Learning and Student Placement Procedure

Intent

James Cook University (JCU; the University) has a responsibility to its students undertaking Work Integrated Learning (WIL) including 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 to ensure JCU has the necessary legal and regulatory requirements in place relating to student placements and work integrated learning (WIL). This 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.

This Procedure addresses Higher Education Standards Framework (HESF) Standard 2.3: Wellbeing and Safety, and Standard 2.4 Student Grievances and Complaints.

Scope

This Procedure applies to JCU students and staff that are involved in placements that are undertaken as part of a JCU course including eligible PhD internships.

This Procedure does not apply to field trips (refer to WHS-PRO-015 Field Trip Procedure).

This Procedure does not apply to the placement of students by the Singapore or Brisbane campuses, or JCU Controlled Entities.

Definitions

Except as otherwise specified in this Procedure, the meaning of the terms used are as per the Work Health and Safety Policy or the Policy Glossary.

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 WIL; and
• other persons whose activities are influenced by the student while undertaking placement and WIL.

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  Academic Placement Coordinator

Academic Placement Coordinators are responsible for ensuring that:

• risk profiling is completed for the placement activity for a group of students and where required for individual students;
• 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 Staff Code of Conduct, including ensuring that written consent is obtained prior to disclosure to third parties. Note: administrative processes related to the collection and storage of student personal information are managed by the Student Placement Team or the WIL Administration Team;
• an evaluation of a placement host’s ability to provide a placement that is safe and meets course learning outcomes is undertaken prior to each Placement;
• placements are monitored at periodic intervals; and
• placements are recorded in the JCU Placement Management system. Note: the associated administrative functions are undertaken by the Student Placement Team or the WIL Administration Team.

Academic Placement Coordinators may engage Academic Services to complete administrative and other duties on their behalf, but remain responsible for those duties.

1.3  Students

Students must not 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 (WHS) 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  health and safety advisory function in relation to placements.

This is done through:

• development and implementation of this procedure; and
• provision of support, advice, guidance and training to assist Academic Placement Coordinators and other stakeholders to undertake their duties, obligations and responsibilities as 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 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

JCU requires a risk-based approach to placements be taken, which ensures that requirements for lower risk placements are minimised, while resources are concentrated on those placements determined to be higher risk.

The following six health and safety factors must be utilised (at a minimum) to assist in determining the risk profile for placements:

• Work Factors: Work factors 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 may include professional knowledge and expertise of the student.

• Travel and Transportation Factors: Driving and travel when undertaking activities for the placement host may present 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 their accommodation, as well as during placement activities.

• Location and/or Region Factors: The location of the placement can have considerable risk 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: Individual student factors including health, knowledge, skills, experience and personality may impact 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, where reasonably practicable. JCU will work with placement hosts to ensure that access and support requirements will be provided for the student on placement, where required and reasonably practicable. JCU encourages students who 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 hosts. JCU AccessAbility provides individual advice and support for students requiring adjustments for placements.

• Insurance Limitations: Insurance is a means of transferring risk by paying for the provision of professional support and financial compensation if things go wrong. All risk assessments 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 Risk Profiling Tool (Appendix A) and Risk Assessment Template (Appendix B) provides guidance to business units to assess the 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 risk profile of the placement host can be evaluated against the number scale of the JCU Risk Rating Matrix (Appendix C). 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 placement hosts with a medium or high risk assessment based on the risk appetite of the University.

When conducting risk assessments, it is appropriate to involve people with relevant knowledge of the practices and health and safety issues associated with the activities a student may be involved in. This is particularly relevant in the case of placements with higher risk profiles.

An example of a low-risk placement include an office-based placement.

Some examples of medium risk placements include industrial, laboratory or nursing placements where higher work-related risks are present, 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 include construction, forestry, agricultural, medical or dental placements where 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.

2.1.1 High risk placements

Placements with a high risk rating assessment must consult the WHS Unit, and must include evaluation of the placement host’s health and safety processes using the Student Placement Health and Safety Proforma (Appendix D). Business units are encouraged to tailor the checklist to their needs before providing to the placement host.

3. Incidents during Placement

All WHS incidents that occur during student placements must be entered into Riskware by the Academic Placement Coordinator as soon as practicable after the College has responded. The University’s Incident Management Policy and relevant procedures may also apply for notification and response actions. It is the responsibility of the Academic Placement Coordinator to follow up with the student following any incident to confirm their health and wellbeing.

4. Post Placement

Health and safety must be included as part of each post-placement debrief or evaluation process with students, in order to provide the Academic Placement Coordinator with more information about the health and safety environment of placement hosts for future placements.

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

5. Monitoring and assuring the academic quality associated with Placement

In accordance with the Curriculum Committee’s Schedule of Business, An annual report detailing all third-party agreements (including collaborative and commercial ventures that are not WIL-based), will be presented for review and must include:

• Numbers of WIL arrangements with Third-parties occurring over the previous year including student participation numbers,
• Student success and satisfaction of supervision in WIL activity,
• Any significant issues resulting from WIL activities in the previous year; and
• Any recommendations devised to improve WIL activity to assure compliance with HESF 5.4.

Related policy instruments

WHS-PRO-015 Field Trip Procedure

WHS-PRO-002 Work Health and Safety Risk Management Procedure

WHS-PRO-005 WHS Incident and Hazard Management Procedure

Incident Management Policy

Staff Code of Conduct

Student Code of Conduct

Schedules/Appendices

Appendix A: Risk Assessment Profiling Tool

Appendix B: Risk Assessment Template

Appendix C: Risk Level Ratings

Appendix D: Student Placement Health and Safety Proforma

Administration

NOTE:  Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Revision History