Work Experience Placement Vetting Policy

Transcription

1 Work Experience Placement Vetting Policy Prepared by: Director of Health and Safety Policy Approved by: Shadow Board Minute No: Impact Assessed 22 May 2013 AOS Aim 6 Implemented: August 2103 Review Date: February 2018 Page 1

2 Contents Page 3 Page 4 Page 4 Page 4 Page 5 Page 5 Page 6 Page 7 Page 8 Page 8 Page 9 Page 10 Page 11 Page 11 Page 12 Preamble to the policy 1- Introduction to the policy 2 Scope and Purpose 3 Vetting 4 Re-Vetting 5 Dormant Places 6 - Contract between the College and Employer/Placement 7 Monitoring Visit 8 Risk Banding 9 - Organisational Risk Definitions for Employer Placements 10 Monitoring following the first Monitoring Visit 11 Prohibitions 12 Auditing 13 Sub Contract Appendix Page 2

3 Preamble to the Policy Equal Opportunities The College shall comply with all statutory duties in respect of equal opportunities in the areas of sex, race, age, disability, sexual orientation, transgender, religion, belief, pregnancy, maternity and paternity, marriage and civil partnership and the rehabilitation of offenders. The college shall also comply with the Human Rights Act 1998 and any subsequent enactments or modifications. Sustainability The college will comply with all statutory duties in respect of sustainable development by seeking to improve the long-term economic, social and environmental wellbeing of people and communities. This needs to be done in ways which promote social justice, equality of opportunity and which enhance the natural and cultural environment while respecting its limits. Welsh Language The College will comply with its Welsh Language Scheme, which is a statutory document, in all of its activities. This includes conducting Welsh Language Impact Assessments for all new and revised policies and initiatives. Page 3

4 1. Introduction to the Policy a. This policy and the procedures that accompany it in the supporting appendices are designed to assist staff in the management of health and safety within the Work Placement environments. 2. Scope and Purpose a. The purpose of vetting the health and safety standards of a potential Employer/placement is to be satisfied, so far as is reasonably practicable, that the learner is not going to be exposed to an unacceptable level of risk. b. The Welsh Government Department for Education and Skills (DfES) requires all training providers to comply with the Code Of Practice which details the requirements for placing learners at work placements. In practical terms this means: c. Visiting the location where the learner is going to undertake work or training/learning so as to complete a systems assessment and observe the physical conditions, environment and working practices as they affect the learner. d. In the case of peripatetic work, conducting a health and safety management system assessment. Following the vetting, which typically may take place at the Employers/placement main business location, a judgment needs to be made on whether a visit to a typical site is required before contracting. e. For providers who have employers/placements with multi-sites and these Employers/placement have robust corporate policies and systems that cover all sites, then only one site needs to be vetted. 3. Vetting a. The Vetting Request form (VR1) is completed prior to the learner being placed and initiates a checking process to determine whether the host employer / placement in question requires a vetting / monitoring or is safe to proceed with. (This form is available on the Extranet). Page 4

5 b. The vetting must take place before placing a learner or agreeing funding for an employed learner. The vetting should take into account the type of work the learner will be doing and the areas where the learner will be working. c. The vetting is only to be undertaken by trained and competent staff. A list of competent staff who have received training is available from the health & safety department. Staff that require training can also receive this from the health & safety department. d. Initial vetting is to be undertaken using the Work Placement - Initial Vetting Visit Form (The latest format of this form can be found on the Health & Safety section of the Extranet). The competent member of staff should be able to recognise hazards and risks in the occupational areas they are dealing with. The vetting form must be completed correctly with comments provided against each subject area as necessary. If a Not satisfactory is applicable, then an appropriate account of the necessary remedial action (comment) and action plan must be recorded on the form. In the event that a Not Satisfactory is given and no remedial action is recorded then no placement can be made at that premises / company. e. Any recommendations or improvements that have been agreed with an employer following a vetting or monitoring visit, and any action plans discussed and arranged must be noted on form VF2 Development Plan (The latest format of this form can be found on the Health & Safety section of the Extranet). f. Vetting records of in-use employers / placements must be retained for at least 4 years. It is advisable that these records be appropriately stored centrally within the Faculty area. 4. Re-Vetting a. Re-Vetting needs to occur in the following instances: At a maximum of 4 years from the previous visit. When an employer/placement remains dormant for longer than its dormancy timescale (refer to Dormant Places within the Policy for risk banding timescale clarification) and it needs to be reused. Major changes in the structure, environment, undertaking etc of the Employer/Placement Significant issues found following an accident/disease investigation. 5. Dormant Places a. A register of dormant places will be kept. Ideally this will be located on the Health & Safety database. Before placing a learner, the dormant data file must be Page 5

6 checked to ensure the Employer/Placement has not been dormant for more than the timescales indicated below. b. If it has been dormant for a length of time greater than those specified below then an initial full health and safety vetting needs to be undertaken. HIGH Combined Risk Employers/Placements banded in this category should be re-vetted prior to recommencement of learning/work experience not more than 12 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period may necessitate monitoring to be undertaken. MEDIUM Combined Risk Employers/Placements banded in this category should be re-vetted prior to recommencement of learning/work experience not more than 24 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period would necessitate monitoring to be undertaken. LOW Combined Risk Employers/Placements banded in this category should be re-vetted prior to recommencement or learning/work experience not more than 48 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period would necessitate monitoring to be undertaken. 6. Contract between the College and the Employer/Placement a. All employers / placements have a responsibility for the health, safety and welfare of the learner on work experience and must therefore ensure: Compliance with relevant health and safety legislation. Adequate employer s and public liability insurance cover in respect of the employer's activities and that of the learner whilst at work. Every learner is protected and supervised at work from any risk to his or her health and safety, which is a consequence of their lack of experience, or absence of awareness of existing or potential risks. A health and safety policy is in place, as required by law. Risk assessment process is in place, as required by law. Provision of competent persons with responsibility for health and safety. Page 6

7 Learner induction every learner whether employed or on work experience is provided with a comprehensible induction and training as appropriate. Provision of necessary personal protective equipment (PPE), free of charge, and ensure its proper use at all times. Provision of safe and healthy : I. Working/learning environments II. Equipment, materials III. Systems of work IV. Welfare facilities V. Emergency arrangements All accidents and occupational disease affecting the learners are reported to the College immediately, contacting the College Health and Safety Department on or If the incident is classified as reportable under RIDDOR the reporting procedure as defined by the Health and Safety Executive must be followed in addition to informing the College. b. All the requirements are set down in the form of an Agreement, which can only be entered into by a suitably senior person at the Company or Organisation, and who has the authority to do so on behalf of that Company or Organisation. c. Only suitably trained Coleg y Cymoedd employees have the authority to enter into an agreement with a Company or Organisation relating to a placement - a full list of authorised employees are available from the Health & Safety Department. d. On completion of suitable and satisfactory vetting, the Agreement must be completed prior to any learner starting at the provider. Please note the contract is placement specific and would need to be renewed every occasion an initial vetting is undertaken. 7. Monitoring Visit a. From commencement of learning, or directly after the Learner is placed with an Employer/Placement a first monitoring visit should be conducted. The Monitoring Form (The latest format of this form can be found on the Health & Safety section of the Extranet) should be completed by the competent person during the monitoring visit. b. The first monitoring visit should cover: Any outstanding matters or remedial action identified from the initial vetting, which are addressed, or are in the process of being addressed. Page 7

8 The working environment of the learner, to observe and confirm that standards have been maintained (premises, environment, working practices etc.). The learner s personal safety and welfare needs have been addressed. c. Discussions should take place with the Employer/Placement (learner s supervisor) and the learner to confirm: Documented induction has been carried out and the Learner is aware of the risks and control measures, emergency arrangements etc. Supervision is in place as agreed and working in practice. Prohibitions are understood by the learner and supervisor. Personal Protective Equipment has been provided and used as agreed. On-going information, instruction and training is being given as appropriate. Evidence of learner s understanding. d. A record should be kept of the first monitoring visit. 8. Risk Banding a. The first monitoring visit should be determined by the risk banding, established during/after the vetting visit has been conducted. The first monitoring visit should then be undertaken to the following time-scales: Combined - visit within the first 3 weeks Combined Medium - visit within the first 8 weeks Combined Low - visit within the first 13 weeks b. Occupational risk levels should be established from Annex 3 Classification of Activities (Occupational Risk) of the National Council for Education and Training for Wales Health and Safety Code of Practice. (They are also enclosed within the Work Placement - Initial Vetting Visit Form). 9. Organisational Risk Definitions for Employer Placements a. Low Risk Demonstration of high standards of health and safety management. Detailed evidence of compliance with health and safety contractual requirements. b. Medium Risk Demonstration of basic standards of health and safety management. Minimal level of compliance with health and safety contractual Page 8

9 requirements. Improvements required in accordance with an agreed Development Plan. c. Risk Demonstration of poor standards of health and safety management. Insufficient compliance with health and safety contractual requirements. Significant management improvements necessary, but risk of immediate danger to the learner is low. Development Plan with strict time-scales should be agreed. d. Defer Demonstration of poor standards of health and safety. Insufficient compliance with health and safety contractual requirements. Significant management improvements necessary, as risk to learners is high. Deferred until a substantial Development Plan with strict time-scales has been agreed and completed. e. Unacceptable the organisation s attitude and/or non-compliance with health and safety requirements determines the Employer/Placement unacceptable. Unable to agree a Development Plan. Organisational Occupational Risk Matrix est Occupational Risk Level Low Medium Organisational Low L L M Risk Medium L M H Level H H Defer f. When the prospective learner is already in employment, vetting and the first monitoring visit can be conducted at the same time. Although agreements might have been reached during vetting, it is impossible to judge how effective they have been until the initial monitoring visit. g. If standards have dropped to an unsatisfactory level, since the vetting visit, then immediate action should be taken to cease learning and/or issue a Development Plan. 10. Monitoring following the first Monitoring Visit a. The next stage of monitoring is also determined by the risk banding, established after the vetting has been conducted, and under-taken to the following timescales: Combined - visit within 3 months of vetting date Combined Medium - visit within 6 months of vetting date Page 9

10 Combined Low - visit within 12 months of vetting date b. If the Employer/placement was initially deferred until an agreed Development Plan was completed, the frequency should be determined from the date when the Development Plan was completed. c. Monitoring should include: Any outstanding matters or remedial action identified from the initial vetting, which are addressed, or are in the process of being addressed. The working environment of the learner to observe and confirm that standards have been maintained (premises, environment, working practices etc.). The learner s personal safety and welfare needs have been addressed, including: Awareness and understanding of the risks and control measures, emergency arrangements etc; Supervision is in place as agreed and working in practice: Prohibitions are understood by the learner and supervisor Personal Protective Equipment/Clothing has been provided and worn as agreed; On-going information, instruction and training is being given as appropriate d. A record must be kept of the monitoring visit. e. The frequency of subsequent monitoring will depend on the outcome of the previous visit. 11 Prohibitions a. This is an agreement that stops a learner from using defined equipment, vehicles, materials, or from entering defined areas, where the lack of competence, training etc. would endanger that person. NB. Although the College has no authority to impose prohibitions on Employers/Placements it does have a contractual obligation to assure the National Council that if prohibitions exist that they are understood and agreed by all relevant persons, and as such provide the National Council with evidence to this effect. b. The Work Placement Prohibition Form (The latest format of this form can be found on the Health & Safety section of the Extranet) should be used when there Page 10

11 is a need to impose a prohibition on employers / placements. A record of the completed form should be kept for 4 years. 12. Auditing a. The initial vetting forms have an auditing section at the rear of the form. A designated person within the Faculty area or department should be appointed and trained to audit the forms. b. If any issues are found then these should be clearly recorded and communicated back to the person who carried out the vetting. These issues should then be addressed and resolved by the person who carried out the initial vetting. Once these have been completed the form should once again go back to the auditor to ensure compliance. c. In addition the whole above procedure should be audited on at least a 12month basis, with a representative sample of the documented forms such as the Work Placement - Initial Vetting Visit Form being audited by the Director of Health & Safety or other appropriate appointed person. 13. Sub Contract Arrangements a. All contracts between Coleg y Cymoedd and Sub Contract providers must include as a minimum, the Health and Safety requirements as detailed in the Welsh Government Department for Education and Skills Health and Safety Code of Practice for Contracted Provision, section 9.2. b. A full review is to be undertaken of all Sub Contract Providers, to review and test that the sub contract arrangements are being undertaken in accordance with the Code of Practice for Contracted Provision. c. Coleg y Cymoedd must ensure that a separate written contract exists for each employer/placement and sub-contract provider. d. The contract between the employer/placement and sub-contract provider, must include as a minimum, the criteria detailed in the Welsh Government Department for Education and Skills Health and Safety Code of Practice for Contracted Provision, section 9.2. (Appendix 1) Page 11

12 COPY OF ANNEX 1, 2, 3 & 4 of WELSH GOVERNMENT, DEPARTMENT for EDUCATION and SKILLS HEALTH & SAFETYCODE OF PRACTICE for CONTRACTED PROVISION Annex 1 Vetting Employers/Placements The following information is given to assist Providers and Sub-contract Providers (through the Provider) in identifying the health and safety standards expected at Employer/Placement. The list is general and not exhaustive: A1.1 General Requirement Adequate Employers and Public Liability insurance is in place. A1.2 Safety Policy and Risk Assessment (a) (b) (c) There is a health and safety policy (statement, organisation and arrangements) which must be in writing where required by law. Risk assessments have been undertaken and recorded where required by law. Appropriate procedures/control measures have been introduced as a result of the risk assessments. A1.3 Staff Competencies (a) There is access to a competent person to assist learners in matters of health and safety. (b) Supervisory personnel have a detailed knowledge of the occupational area and are aware of the hazards and risks involved. A1.4 Learning Environment (a) A safe and healthy learning environment is provided, including adequate welfare facilities. A1.5 Equipment, Materials and Safe Systems of Work (a) (b) Suitable safe equipment and materials are provided with safe systems of work and control measures as appropriate. Appropriate Personal Protective Equipment is issued where required and at no cost to the learner. A1.6 Learner Provision Page 12

13 (a) (b) An effective method for ensuring an adequate health and safety induction, and subsequent on-going health and safety training, for the learner is in place. Induction covers at least the following: employer s legal responsibilities learner s legal responsibilities (to themselves and others including cooperation with their employer/placement) the significant risks identified from the risk assessments the control measures devised the health and safety policy, organisation and arrangements emergency and fire arrangements prohibitions, rules, do s and don ts accident, ill-health and other incident reporting arrangements first aid arrangements arrangements for the provision and safe use of personal protective equipment (clothing) supervision arrangements arrangements for the safe use of equipment and machinery arrangements for the protection of learners in relation to the use of any hazardous substance; manual handling hazards and protective measures (c) The learner s induction and other appropriate health and safety training, information and instruction are recorded. A1.7 Accident and Disease Investigation and Reporting (a) (b) (c) There is a system for the recording, investigating and reporting of accidents, diseases and dangerous occurrences (both statutory and contractual). Duties to report accidents, diseases and dangerous occurrences are well known. Accidents, diseases and dangerous occurrences will be investigated by a competent person. A1.8 Emergency Planning Adequate emergency arrangements are in place and these are maintained and tested. A1.9 The Purpose of Vetting The purpose of vetting is to evaluate the Employer s/placement s management of health, safety and welfare, to ensure learning/work experience is undertaken in an acceptable environment with risks managed. In practical terms this means: Page 13

14 Assessing the employer s/placement s policy and procedures, inspection and maintenance systems etc. to gain assurance that health, safety and welfare is managed. Observe the physical conditions, environment and working practices as they may affect the learner. In the case of peripatetic work, where the vetting may typically take place at the employer s/placement s main business location, a judgement needs to be made on whether a visit to a typical site is required before contracting. For providers who have employers/placements with multi-sites and these employers/placements have robust corporate policies and systems that cover all sites, then only one site needs to be vetted. It is preferred that the vetting is undertaken at the head office Page 14

15 Vetting Employers/Placements Flowchart The following process must be followed PRIOR to Employer/Placement being funded. Employer/Placement is identified Arrange vetting visit and establish scope f i it Conduct visit and record findings Provider establishes a combined risk banding Unacceptabl e Deferred HIGH MEDIUM LOW Development Plan required and Is a development plan required? YES NO Suitable Progress has been made Development Plan Agreed Reject Employer/Placeme NO Y Employer/Placement Accepted If necessary Page 15

16 Annex 2 Risk Banding Employer/Placements Using the information and matrix below, Providers should combine the Occupational and Organisational risk levels to reach an overall risk banding decision. The Combined Risk Band determines the frequency of monitoring. Occupational risk levels should be established from the `Classification of Activities (Occupational Risk) on page 31. Organisational Risk Definitions Low Risk Demonstration of high standards of health and safety management. There is detailed evidence of compliance with health and safety legal requirements. Medium Risk Demonstration of basic standards of health and safety management. There is a minimal level of compliance with health and safety contractual and legal requirements. Improvements required in accordance with an agreed Development Plan. Risk Demonstration of poor standards of health and safety management. There is insufficient compliance with health and safety contractual and legal requirements and significant management improvements are necessary. Development Plan with strict time-scales agreed. The organisational risk banding can change upon sufficient progress or completion of development plans, or an increase in risk through previously unforeseen or increased shortfall, thereby affecting Combined Risk Banding and frequency of monitoring. Defer Demonstration of poor standards of health and safety. There is insufficient compliance with health and safety contractual and legal requirements and significant management improvements are necessary, as risk to learners is high. The Employer/Placement is deferred until adequate development, with strict time-scales, has been agreed and progressed. Unacceptable The Employer s/placement s attitude, non-compliance with health and safety requirements and/or ability to agree a development plan determines them unacceptable. Organisational/Occupational Risk Matrix est Occupational Risk Level LOW MEDIUM HIGH Organisational Risk Level LOW L L M MEDIUM L M H HIGH H H DEFER Page 16

17 Classification of Activities (Occupational Risk) ADMINISTRATION AGRICULTURE, HORTICULTURE, FISHING AND FORESTRY ANIMAL NURSING ANIMAL CARE (including Retail) CARE CATERING (Kitchen) CHEMICALS AND CHEMICAL PRODUCTS CONSTRUCTION EDUCATION ELECTRONICS ENGINEERING (Mechanical & Electrical) EQUESTRIAN HAIRDRESSING/BEAUTY HOTELS AND RESTAURANTS (Non-catering) MANUFACTURING/CRAFT MINING AND QUARRYING OUTDOOR ACTIVITIES PRINTING REPAIR OF MOTOR VEHICLES, MOTOR CYCLES RETAIL TRADE SALES SECURITY SPORT/RECREATION & LEISURE TEXTILES/CLOTHING TRANSPORT UTILITIES WHOLESALE AND WAREHOUSING Risk Levels Low Medium Medium Low Medium Medium Medium Medium Low Low Medium Medium Medium Page 17

18 Annex 3 Re-vetting Dormant Employers/Placements When funded learning or work experience ceases with an employer/placement the Provider may retain the contact on a database for future use. In this instance the employer/placement is identified as being dormant. As the vetting and/or monitoring documentation completed in respect to the employer/placement may still be relevant when learning/work experience resumes there may not be a requirement to re-vet. However there may be a need to monitor. Example: It has been identified by the provider that funded learning will recommence with an employer/placement after a period of five months dormancy. The last monitoring visit undertaken three months prior to dormancy identified the employer/placement as having a combined medium risk band (occasioning monitoring every six months). As the last health and safety check was 8 months prior to the proposed recommencement of learning a monitoring visit would be required on the day of recommencement. Providers should include dormant employers/placements within their tracking system, comprising the date of dormancy start, the Employer/Placement combined risk band, together with a pre-determined date of expected re-vet if learning/work experience were to recommence. In respect to re-vetting, there are prescribed periods of dormancy which would require a re-vet to be undertaken. These periods are determined by the combined risk at vetting or monitoring. HIGH Combined Risk Employers/placements banded in this category should be re-vetted prior to recommencement of learning/work experience not more than 12 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period may necessitate monitoring to be undertaken. MEDIUM Combined Risk Employers/placements banded in this category should be re-vetted prior to recommencement of learning/work experience not more than 24 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period would necessitate monitoring to be undertaken. LOW Combined Risk Employers/placements banded in this category should be re-vetted prior to recommencement or learning/work experience not more than 48 months of becoming Dormant, or any period following this duration. Recommencement of funded learning prior to this period would necessitate monitoring to be undertaken. Page 18

19 Annex 4 Monitoring Employers/Placements Providers who have no contractual responsibility for learners, at employers/placements, following the vetting process, other than to investigate/report accidents/diseases, are not required to monitor the Employer/Placement. This does not exclude the Provider from the requirements in Annex 3. Employers/placements used for work experience, whereby the work experience is completed before the frequency of monitoring is due, do not require to be monitored see A4.2 for determination of the required frequency. If the vetted Employer/Placement is used more than once, either consecutively or sporadically between the period of vetting and re-vetting, then monitoring would be required. When Monitoring Is Required Monitoring should only be undertaken when the employer/placement has been accepted, accepted with a development plan, or, in the case of a previously deferred employer/placement, when suitable progress has been evidenced against the development plan whereby the combined risk band is lowered to high risk. A4.1 The first monitoring visit of an employer/placement should be undertaken using the following timescales: Combined - visit within the first 3 weeks of the vetting/re-vet date Combined Medium - visit within the first 8 weeks of the vetting/re-vet date Combined Low - visit within the first 13 weeks of the vetting/re-vet date A4.2 The first monitoring visit for learners should include: The employer s/placement s general and/specific induction The working environment of the learner, to observe and confirm that the health and safety management system assessed during vetting is implemented The learner s personal safety and welfare needs have been addressed Any outstanding matters or remedial action identified from the initial vetting, which are addressed, or are in the process of being addressed A4.3 All subsequent monitoring of employers/placements should be undertaken using the following timescales: Combined - visit within 3 months of vetting date and every subsequent 3 months unless the risk banding changes or a re-vet is required. Combined Medium - visit within 6 months of vetting date and every subsequent 6 months unless the risk banding changes or a re-vet is required. Page 19

20 Combined Low - visit within 12 months of vetting date and every subsequent 12 months unless the risk banding changes or re-vet is required. A4.4 Monitoring of employers/placements providing work experience is only required when work experience occurs after the required date of first monitoring, which is determined by the risk-band at vetting see 8.11 for the requirement to track monitoring following vetting. A4.5 Subsequent monitoring of employers/placements providing work experience is only required if work experience occurs on or following a required date, determined by the risk-band at vetting see.8.11 for the requirement to track monitoring following vetting. A4.6 The frequency of monitoring, after re-vetting, should be determined from the re-vetting date, with the first monitor undertaken against criteria in A4.1 or A4.2, and subsequent monitoring against criteria in A4.4. A4.7 Generally, a monitoring visit should cover: (a) (b) (c) any outstanding matters or remedial action identified from the initial vetting or monitoring which are addressed, or are in the process of being addressed. the working environment of the learner, to observe and confirm that standards have been maintained (premises, environment, working practices etc.). the Learner s personal safety and welfare needs have been addressed. A4.8 Discussions should take place with the employer/placement (learner s supervisor) and the learner to confirm: - documented induction has been carried out and the learner is aware of the risks and control measures, emergency arrangements etc. - supervision is in place as agreed and working in practice; - prohibitions are understood by the learner and supervisor; - PPE has been provided and used as agreed; - on-going information, instruction and training is being given as appropriate; - evidence of Learner s understanding. A4.9 Every health and safety monitoring visit should be recorded. A4.10 If standards have dropped to an unsatisfactory level, since the vetting or previous monitoring visit, then immediate action should be taken to cease learning and/or issue a development plan. A4.11 If the employer/placement was initially deferred until sufficient progress has been made against the development plan, the frequency of monitoring should be determined from the date when the learner was placed with the employer/placement. Page 20

21 A4.12 The risk banding of employer s/placements can change following monitoring, but only when sufficient development has been closed out, or there is an increase in risk through previously unforeseen or increased shortfall. A4.13 The provider should also ensure that learner accidents/diseases, where shortfall was found in the investigation, contribute to change in risk banding and subsequent monitoring. A4.14 Monitoring within a period following dormancy, but before the employer/placement is required to be re-vetted, should be undertaken following the pre-determined frequency following vetting. If the period of dormancy has extended beyond the frequency of monitoring then a monitor should be undertaken on the recommencement day with the employer/placement see example at Annex 3 Monitoring is undertaken to test the implementation of the employer s/ placement s health and safety management system. It is tested through the viewpoint of the learner, but this does not mean that every learner is monitored. If there are several learners at an employer/placement then only one learner is used to complete the monitor. It is advised in the instance of an employer/placement with more than one learner to vary or alternate the learners used in the monitoring process, and if appropriate starting with the learners undertaking the highest risk occupational route/activity. Page 21

22 Monitoring Employers/Placements Flowchart Review Vetting Information Arrange and undertake first monitoring visit, following frequency Combined Risk Combined Medium Risk Combined Low Risk Have standards dropped to an unsatisfactory level? Immediate withdrawal of funded learning YES NO Re-Vet if necessary Development Plan Issued Subsequent Monitoring Review information from vetting visit and first monitoring visit. Arrange and undertake monitoring visit. HIGH MEDIUM LOW Learners should be monitored within 3 months. Learners should be monitored within 6 months. Learners should be monitored within 12 months. Risk banding will need to be kept under review in all categories to reflect health and safety performance Page 22