Students on Unpaid Work Placement

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Procedure Number: OHS 019Procedure Title: Students on Unpaid Work Placement
Supersedes Existing Procedure: YProcedure Sponsor: Vice-President, Human Resources and Equity, Diversity and Inclusion
Associated Policy: NProcedure Owner: Organizational Health and Wellness Specialist
Next Review Date: November 2020Date Last Approved by the CET: November 29, 2017
Related Documents and Links
1. Purpose

To outline the process to ensure that students on unpaid work placements are eligible for insurance coverage if they suffer a work-related accident or illness and to detail the reporting responsibilities in the event of an injury or illness while a student is on an eligible placement.

2. Application
  • 2.1 Placements Eligible for MAESD Funded Insurance:
    • The Ministry of Advanced Education & Skills Development (MAESD), formerly called the Ministry of Training, Colleges & Universities (MTCU) covers the cost of accident insurance coverage for Loyalist students (“trainees”) placed with employers in order to obtain work skills and experience, as long as certain criteria are met (see 2.4 and 2.5).\
    • The accident insurance coverage will either be from Workplace Safety and Insurance Board (WSIB) if the placement site currently has WSIB coverage or limited insurance coverage by Chubb Insurance (see section4.4), if the placement site is not covered by WSIB.
    • MAESD will cover eligible out-of-province or out-of-country placements.
  • 2.2 Placements in WSIB Covered Workplaces but Ineligible for MAESD Funded Insurance:
    • If a placement is not eligible for MAESD funded accident insurance coverage (because the program is not funded by MAESD), but is a WSIB covered workplace, the trainee must be provided with WSIB coverage by the placement host. If the placement host is unwilling to cover the placement student under their WSIB coverage, Loyalist College can elect to provide coverage.
  • 2.3 Placements in a Workplace Not Covered by WSIB and Ineligible for MAESD Funded Insurance:
    • If a placement is not eligible for MAESD funded accident insurance coverage, and is not a WSIB covered workplace, the trainee is covered by Loyalist College-funded private accident insurance with limited coverage (see section 4.4).
  • 2.4 For a “Student Trainee” to be Eligible for MAESD Accident Insurance Coverage:
    • The placement must be authorized by a Loyalist College department,
    • The student must be enrolled in a Loyalist College program that is funded through MAESD operating grants, has a placement element that is formally assessed as part of the program (either required or optional) and successful completion of the placement is required for completion of the program,
    • The placement is a non-classroom activity,
    • The placement employer does not pay the student a salary,
    • The placement is not with Loyalist College (or other Ontario publicly funded college),
  • 2.5 Student Trainees do not include:
    • Students who on their own initiative volunteer their services to an employer to develop marketable work skills,
    • Volunteers who offer their time or services for community or charitable purposes,
    • Students on an employer’s premises solely for the purpose of visiting or casual observation and who at no time participate in activities of the employer’s industry,
    • Students who, as part of their programs, do unpaid research for Loyalist College,
    • Students when in the classroom portion of their training program,
    • Students who are not on placement but as part of college program perform work at the college,
    • International students who do a placement in their country of primary residence.
3. Roles and Responsibilities

Placement Facilitator

For the purposes of this procedure, a placement facilitator is defined as those faculty members or support staff who are responsible for, arrange for, or complete paperwork for, student placements. It is the responsibility of the Dean of the respective academic departments to determine how the activities are apportioned.

The Dean of the respective academic departments is responsible for communicating the requirements of this procedure to the placement facilitators and for ensuring that the requirements of the procedure are completed.

Placement Facilitators

  • Arrange for safe and suitable work placements for student trainees.
  • Ensure all pre-placement authorizations have been distributed, completed and have the required signatures and are filed at Loyalist College.
  • Act as liaison with trainees and placement employers,
  • Ensure the Organizational Health and Wellness Specialist receives the appropriate paperwork if a trainee is injured while on placement.

Organizational Health and Wellness Specialist

  • Receive reports of student injuries while on placement from placement coordinators and verify that the necessary documents and information has been submitted by the responsible parties to satisfy the claim requirements (if applicable). If required, file a claim for accident benefits for the injured placement student.
  • Act as a liaison between the insurance company (WSIB or private) and the departmental placement facilitators with respect to insurance coverage, claims information, and/or return-to–work planning activities for the injured student.
  • Retain copies of incident and claims-related paperwork for injured placement students.
  • Review and update this policy as needed.
4. Procedure

4.1 Prior to Placement, the Placement Facilitator will:

  • When arranging work placements, review the workplace safety practices at the potential placement employer’s worksite prior to sending student trainees to that workplace.
    • Ensure the student trainees are aware that, under the Occupational Health & Safety Act, they are considered “workers” with all the rights and responsibilities of paid workers; familiarize the student learners with these rights and responsibilities.
      • Note: The on-line Worker Health & Safety Awareness in 4 Steps module available on the Ministry of Labour website is a good tool to provide this mandatory training. At the completion of the training the student can print off a certificate of completion.
    • Acquaint the student trainees with the hazards in the placement site and encourage the trainee to alert their placement site supervisor immediately if they see something that could endanger their safety.
    • Ensure trainees know that if they drive their own vehicle while on placement business that their own auto insurance coverage applies. If a placement site requires that a trainee drive as a part of the placement (either their own or a placement site vehicle), encourage the placement site to request a driving record for the trainee through the Motor Vehicle License Bureau. Drivers should have a full “G” license and have a clean driving record.
    • Ensure trainees have read and signed Form B Student Declaration of Understanding so that they know they are eligible to make a claim for benefits and that their personal information will be shared with MAESD and/or the respective private insurance agency in the event they are injured or contract an illness while on an eligible placement. Retain copies of this form and provide a copy to the placement employer (see section 4.2).
    • Advise trainees what their reporting responsibilities are if they are injured or contract an illness while on placement.
    • Confirm with the placement site whether they have WSIB coverage for the period of the unpaid work placement.
    • Ensure the placement employer understands who is responsible for accident insurance coverage for trainees on unpaid work placements and is aware of the reporting procedures in the event the trainee is injured or contracts an illness. Send a completed Form C Letter to Placement Employers to each placement employer for their declaration of understanding of the reporting requirements and the insurance coverage for the learners. Signed originals must be returned to the placement facilitator for filing. Ensure to insert the placement facilitator’s name, department, and contact information in the highlighted sections prior to sending out.
    • In the event that the placement is not eligible for MAESD coverage (because the program is not funded by MAESD), determine if the placement host with WSIB coverage is willing to cover the placement student. If so, ensure the placement site understands that they must submit WSIB premiums for the student. If the placement site is not willing to cover the student, Loyalist College can apply to WSIB to provide coverage. The placement facilitator is responsible to submit the following information to the Organizational Health and Wellness Specialist at least 2 weeks prior to the placement to initiate this process:
      • written approval from the department Dean accepting the financial risk for the placement student(s),
      • placement student name, placement site company name, and brief details about the company,
      • start and end dates for the placement.

4.2 Trainee Confirmation

Prior to placement, the placement facilitator must provide the placement employer with the following information:

  • Student trainee full name, local address, and telephone number,
  • Specific days when the trainee will be at the placement employer’s workplace, and
  • Confirmation that the trainee has been made aware of the conditions of the unpaid work placement. Including a copy of the signed Form B Student Declaration of Understanding for each trainee will satisfy this requirement.

4.3 Liability Insurance Coverage

Loyalist College carries insurance that covers liability arising from the actions of the student while on placement. This liability insurance is applicable to all placements. A certificate of insurance (COI) can be provided to the placement site as proof of this coverage. The college policy coverage can also be extended to add a placement site as an additional insured, if requested. See Appendix A Liability Insurance Coverage for Loyalist College Students for details. This letter may be shared with a placement employer if so requested.

4.4 Private Accident Insurance Coverage

Private insurance coverage is not as extensive or comprehensive as WSIB coverage. If a learner wishes to know the details of the private accident insurance coverage, the applicable brochure may be provided to the learner. Brochures are available as an electronic file with this procedure:

  • MAESD Coverage: Refer to Chubb (Mercer) Training Participant Program – Details of Coverage, Policy SG10284501. This policy provides an accidental death benefit of $100,000 as well as coverage for a variety of other situations.
  • Loyalist College Coverage: Refer to Sutton Loyalist College Group Accident Benefit Summary, Policy # 056/021990A. This policy provides an accidental death benefit of $100,000 as well as coverage for a variety of other situations.

4.5 Out-of-Province or Out-of-Country Placements

Students on placements outside of Ontario are covered by Chubb Accident Insurance plan (if MAESD eligible) or Sutton Group Accident Benefit (if not-MAESD eligible). The student is advised to obtain additional complementary insurance since private insurance does not provide full compensation. It also does not cover emergency health care except if health care is needed because of an accident while participating in the placement. Students opting for out-of- country placements should obtain their own travel insurance and extended health care coverage.

Note: International students attending Loyalist College are not eligible for MAESD accident insurance if their placement is done in their country of primary residence.

4.6 Accident Reporting Requirements

4.6.1 General Reporting Requirements for All Placements:

  • In the event that a trainee is injured while at a placement site, the trainee must immediately report the accident to their placement site supervisor and their placement facilitator.
    • The placement facilitator will ensure that an OHS 006 Form A Supervisor’s Incident Investigation Report is completed. The placement site may use their own incident investigation form or a blank OHS 006 Form A Supervisor’s Incident Investigation Report may be sent to the placement site for their use. The form may also be completed with verbal information received from the trainee and placement site supervisor. The Incident Investigation Report must be completed and the original delivered to the Organizational Health and Wellness Specialist within 48 hours.
    • Accident claims will be filed when a trainee, because of an accident injury:
      • loses time away from their placement or other regular work.
      • receives health care (not first aid treatment).
      • needs modified work for more than 7 days.

4.6.2 Claims for Placements Eligible for MAESD Funded Insurance:

  • See Part 1 of Appendix B Accident Reporting Paperwork Flowchart for a flowchart of the paperwork needed for accident claim reporting if placement is eligible for MAESD funded insurance.
  • The placement facilitator ensures all parties (placement employer, student trainee (and parent or guardian if student is under 18 years of age) and placement facilitator) completes their respective sections on the MCTU Postsecondary Student Unpaid Placement Workplace Insurance Claim Form 13-1352E. When all information and signatures are entered on the MCTU Postsecondary Student Unpaid Placement Workplace Insurance Claim Form 13-1352E, the placement facilitator forwards a copy to the Organizational Health and Wellness Specialist. The completed form must be returned within 3 days of the incident.
  • If the placement site is covered by WSIB, the placement facilitator must also fax or email Form A Letter of Authorization to Represent Placement Employer to the placement site. The completed form must be faxed back to the Organizational Health and Wellness Specialist within 24 hours. Also send a copy of the Form B Student Declaration of Understanding and the Form C Letter to Placement Employer to the Organizational Health and Wellness Specialist.Note: there are special WSIB reporting requirements when a placement trainee is exposed (or possibly exposed) to infectious diseases through a needlestick injury or contact with other bodily fluids. Contact the Organizational Health and Wellness Specialist for more information.
  • If the placement site is not covered by WSIB, the placement facilitator only sends the completed OHS 006 Form A Supervisors Incident Investigation Report, MCTU Postsecondary Student Unpaid Placement Workplace Insurance Claim Form 13-1352E, copy of Form B Student Declaration of Understanding and a copy of the Form C Letter to Placement Employer to the Organizational Health and Wellness Specialist.

4.6.3 Claims for Placements NOT Eligible for MAESD Funded Accident Insurance:

  • See Part 2 of Appendix B Accident Reporting Paperwork Flowchart for a flowchart of the paperwork needed for accident claim reporting if placement is NOT eligible for MAESD funded insurance.
    • If the placement site is covered by WSIB, the placement facilitator forwards a copy of the OHS 006 Form A Supervisors Incident Investigation Report, copy of Form B Student Declaration of Understanding and a copy of the Form C Letter to Placement Employer to either the Organizational Health and Wellness Specialist or the placement site (depending on who has agreed to cover the injured student – see sections 2.2 & 4.1 (last bullet)).
    • If the placement site is not covered by WSIB, the placement facilitator sends the OHS 006 Form A Supervisors Incident Investigation Report, copy of Form B Student Declaration of Understanding and a copy of the Form C Letter to Placement Employer to either the Organizational Health and Wellness Specialist.

4.6.4 Claim and Return-to-Work Management:

  • The Organizational Health and Wellness Specialist will file the applicable claim forms with WSIB and MAESD and/or make the initial contact with Chubb or Sutton Private Insurance.
  • On-going claim management and assistance with return-to-work/school accommodation will be handled by the Organizational Health and Wellness Specialist with input from the placement facilitator.
  • If a trainee, because of the accident, is not able to attend placement or seeks medical treatment or needs modified work for more than 7 days after the initial report of accident, the trainee must advise their placement facilitator, who in turn will advise the Organizational Health and Wellness Specialist. Additional WSIB or private insurance forms may be required.

4.6.5 File Retention:

The original OHS 006 Form A Supervisors Incident Investigation Report and associated private insurance or WSIB forms will be retained by the Organizational Health and Wellness Specialist.

4.7 MAESD Statistics Reporting Requirements (ONLY APPLICABLE for placements eligible for MAESD Accident Insurance):

  • For the purposes of determining Chubb insurance premiums, Loyalist Colleges must report to MAESD the total hours, number of students, and type of industry for those unpaid work placements at employers not covered by WSIA.
  • If international students (on Visa Study authorization) are on work placement, their placement hours must be reported separately to MAESD. MAESD provides insurance coverage for international students.
  • The placement statistics will be collated and reported at the end of each semester to MAESD by the Office of the Senior Vice-President, Academic.
    6. References