Workplace Safety and Insurance Coverage for Students on Unpaid Work Placements Procedure

1. Responsibilities

1.1 Deans, Associate Deans, Managers and Supervisors 

• Ensure that Humber placement coordinators and other employees under their supervision follow the MTCU guidelines and this procedure.
• Ensure that approved program curriculum incorporate awareness training in safe work practices in the field of study.
• Ensure that appropriate resources are provided to comply with MTCU’s requirements and this procedure.

1.2 Humber Placement Coordinators

• Read, understand, and follow this document.
• Attend an information session on the policy, procedure and guidelines as offered through Health and Safety Services.
• Ensure that completed and signed original copies of the Student Declaration of Understanding (Appendix A) and the Letter to Placement Employer (Appendix B) are kept for all placements.
• Ensure that all requirements prior to the commencement of an unpaid work placement are followed as outlined in this document, including providing the Placement Employer with required information on the student trainees (Appendix C).
• Implement the reporting and follow-up process outlined in this document in the event that a student is injured or contracted a disease during an unpaid work placement.
• Coordinate a student’s return to work following an unpaid work placement injury/illness, in consultation with Health and Safety Services.
• Respond promptly to student health and safety-related concerns regarding the placement.

 1.3 Student Trainees 

• Complete and provide the original signed copy of the Student Declaration of Understanding letter (Appendix A) to the Humber Placement Coordinator.
• Complete a Student Work Placement Safety Checklist (Appendix D) and review the findings with the Placement Supervisor.
• Report any safety issues at the work placement to the Placement Supervisor. High-risk or unresolved safety issues are to be reported to the Humber Placement Coordinator.
• Work safely at all times, and participate in and implement all safety-related training and procedures provided by the Placement Employer and Humber.
• In the event of a workplace injury, illness or accident involving the student during the unpaid placement, follow the response and reporting procedures outlined in this document.

1.4 Placement Employers/Placement Supervisors 

• Follow Humber’s procedures and the MTCU guidelines.
• Complete Humber’s Letter to Placement Employer (Appendix B) and indicate whether the placement organization is covered under the Workplace Safety and Insurance Act.
• Provide a safe work environment for student trainees.
• Ensure that students are provided with safety orientation, information, supervision, and protective equipment related to workplace hazards specific to the placement, and that students abide by all safety requirements.
• In the event of a workplace injury, illness or accident incurred by the student during the unpaid placement, follow the response and reporting procedures outlined in this document.

 1.5 Student Health Centre

• Receive the Student Placement Incident Report (Appendix E), review the information immediately, and contact the student to follow up as required.
• Immediately (and at least within 24 hours) provide a copy of the Student Placement Incident Report to Health and Safety Services when the incident report is received.
• Act as a resource to the School, the Humber Placement Coordinator, and Health and Safety Services on matters related to student health incidents during placements.

1.6 Health and Safety Services 

• Administer the accident claim (WSIB or ACE-INA) in the event of a student injury/disease during an unpaid work placement, including appropriate measures for filing a claim with the WSIB and administration of the return to work process.
• Liaise with the student trainee, the placement coordinator, the WSIB, ACE-INA and/or the MTCU on matters related to an injury/disease claim. The WSIB or ACE-INA will contact the student directly regarding his or her claim.
• Liaise with the MTCU on general and claim-specific procedures related to workplace insurance for students on unpaid work placements.
• Develop, schedule and deliver information sessions regarding the Policy, Procedure and steps for implementing the MTCU Guideline.
• Act as a resource to the School, the Placement Coordinator and the Placement Employer on implementation of this Policy and Procedure.

2. MTCU Workplace Insurance Coverage (WSIB and ACE-INA)

2.1 Coverage Eligibility

Humber students must meet the following mandatory requirements in order to be eligible for MTCU insurance coverage:

• The student must be participating in an unpaid work placement.
• The student is participating, however minimally, in the activities of the placement employer’s industry and as such is associated with the health and safety risks of that industry.
• The work placement is arranged or authorized by Humber, and is part of an educational/training program funded or subsidized by the MTCU operating grants.

Students are still eligible for benefits through MTCU even if they receive the following types of payment:

• Social assistance benefits (e.g. through Ontario Works Program)
• Training Allowances
• Honoraria
• Reimbursement of expenses
• Stipends or any money paid to the student by Humber

International students on unpaid student placements are also eligible to receive benefits under WSIB or ACE–INA if they meet all of the eligibility requirements.

2.2 Coverage Ineligibility:

The following students are not eligible for MTCU insurance coverage:

• Students in postsecondary education/training programs that are not funded through MTCU operating grants.
• Students in unpaid placements which are not a required part of the academic program and which they have arranged or organized themselves; such placements are considered volunteer work.
• Students who are paid a salary. Students on a placement who receive wages from the placement employer are considered workers and must be provided with insurance coverage by the placement employer.
• Students whose unpaid work placement is with Humber. Students on an unpaid work placement with Humber will be covered under Humber’s WSIB coverage.
• Students who are in the classroom portion of their training program.
• Students who, as part of a formal course or program, attend a placement with an Ontario Placement Employer but the placement occurs outside of Ontario.

3. Prior to Commencement of Unpaid Work Placements

Schools and departments are responsible for ensuring that the following steps are taken prior to the start of an unpaid work placement.

 3.1 Student Notification

3.1.1 Each student will be provided with a declaration letter that informs them of the following:

Insurance coverage is provided to them through MTCU (WSIB or private insurance) for any injury or illness incurred during an eligible unpaid work placement.

• If they are injured or contract a disease while on the placement, they must report the incident to the Placement Employer and Humber, and they can make a claim for benefits.
• Humber will disclose the student’s personal information relating to the placement and the claim to MTCU.
• They must participate in all safety-related training and implement safety procedures required by the Placement Employer and Humber.
• Humber may provide personal information to the Placement Employer, limited to full name, local address and telephone number, placement schedule and acceptance of the conditions of the placement.

3.1.2 The student will be required to sign the declaration letter and to provide the original signed copy to the Placement Coordinator. The signed copy must be kept in the student’s file.

3.1.3 A template letter, Student Declaration of Understanding, is provided in Appendix A.

3.2 Placement Employer Notification

3.2.1 The Placement Employer will be provided with a letter containing the following:

• A description of the type of coverage available to student trainees on unpaid work placements.
• A request to indicate whether the placement employer has WSIB coverage during the period of the unpaid work placement.
• A description of the WSIB reporting procedures in the event of an injury/disease.
• A link to the MTCU Guidelines and to the Postsecondary Student Unpaid Work Placement Workplace Insurance Claim Form (Appendix F), to be used in the event of a workplace injury/disease.
• For students returning to work after an illness or injury, the requirement to review any restrictions and provide appropriate accommodation to ensure the student’s safe and timely return to the placement.
• The requirement to provide the student with appropriate training and supervision related to health and safety hazards that the student may encounter at the placement organization.

3.2.2 The Humber Placement Coordinator will keep the signed original of the placement letter on file and ensure that Placement Employer has a copy.

3.2.3 A template letter, Letter to Placement Employer, is provided in Appendix B.

3.3 Student Information to Placement Employer Prior to Placement 

3.3.1 When confirming unpaid work placements, Placement Coordinators are required to ensure that the following student information is provided to the Placement Employer prior to the student’s placement.

A. When placing one student with the Placement Employer:

• Full name;
• Local Address and telephone number;
• Specific days when the student will be on worksite and;
• That the student trainee is aware of the conditions of the Unpaid Work Placement.

 B. When placing multiple students with the same Placement Employer, provide a list with (refer to Appendix C for a template):

• Full name of each student;
• Local Address and telephone number of each student;
• Specific days when each student will be on worksite and;
• That the student trainee is aware of the conditions of the Unpaid Work Placement.

3.4 Establish Type of Insurance Coverage (WSIB or Private Insurance) 

3.4.1 Ensure that the Placement Employer has indicated in the Placement Employer Letter (Appendix B) whether the placement organization is covered under the Workplace Safety Insurance Act or not.

Which type of Coverage Applies?

Many organizations that employ workers in Ontario are required to register with the WSIB, however there are exceptions. Examples of employers who are not required to carry insurance with the WSIB include but are not limited to:  membership organizations (such as labour organizations, professional associations, political organizations, etc.), non-profit organizations, and offices of lawyers, dentists, medical doctors and veterinarians. It is important to confirm with each placement employer whether or not they are registered with the WSIB.

3.5 Student Safety

3.5.1 Humber is responsible for ensuring that all student trainees receive appropriate training in safe work practices as part of their academic program. Humber is also responsible for applying due diligence to ensure that students are not placed in unsafe working environments. This can be done by incorporating measures such as:

• A formal agreement between the Humber and Placement Employer as to specific safety measures and training requirements.
• Completion of a Student Work Placement Safety Checklist by the student. A template of a checklist to be used by the student for such purposes is provided in Appendix D. The student will complete the checklist in consultation with the Placement Supervisor. Any identified health and safety issues will be discussed with the Placement Supervisor. Unresolved or high risk health and safety issues are to be brought to the attention of the Humber Placement Coordinator for review.

3.5.2. Placement Employers are responsible for ensuring the safety of student trainees particularly with respect to workplace health and safety hazards that may be encountered at the placement workplace. Placement Employers are required to provide appropriate safety training and orientation, supervision and equipment to protect student trainees from these hazards.

4. Workplace Injuries and Illnesses  

4.1 First Aid

Any injury or illness, however minor, to a student participating in a work experience must be reported by the student to his/her Placement Supervisor and to his/her Humber Placement Coordinator. The report must provide information about the incident, including when, where, the nature of the injury and how it occurred. Incidents which require only first aid treatment do not have external reporting requirements; however, a record of the incident (e.g. Student Placement Incident Report) should be kept on file.  Students are required to follow the reporting procedures outlined in Section 5 (items 1 through 7 only).

First Aid: includes cleaning minor cuts, scrapes or scratches; treating a minor burn; applying bandages/dressing, cold compress/pack, or a splint; and changing a bandage or dressing at a follow-up appointment.

4.2 Health Care/Lost Time

Work related injuries or illness that result in Health Care or Lost Time from a work placement trigger external reporting requirements. The reporting process, and benefits for which the student may be eligible, is determined by the type of insurance coverage for which the student is eligible, either WSIB or private insurance (ACE-INA).

Health Care: includes any treatment that could only be administered by a health care practitioner such as a doctor, chiropractor or physiotherapist; services provided at hospitals and health facilities; and prescription drugs.

Lost Time: means that due to the nature of the injury, the individual has missed time from work beyond the day of the incident.

4.3 Critical Injury

A critical injury includes one of a serious nature that places life in jeopardy, or results in unconsciousness, substantial blood loss, fracture of leg or arm but not a finger or a toe, involves the amputation of a leg, arm, hand or foot but not a finger or toe, major burns to a major portion of the body or loss of sight in an eye. In addition to the requirements outlined in Section 5, critical injuries trigger reporting requirements to the Ministry of Labour. This is a requirement under the Occupational Health and Safety Act of Ontario.

The reporting obligation to the Ministry of Labour for a student critical injury that takes place on the Placement Employer’s premises is the responsibility of the Placement Employer. Health and Safety Services will assist in ensuring that appropriate reporting of the injury takes place. Additional information may be required to determine if an injury is critical. Placement Coordinators should immediately notify Health and Safety Services via telephone at 416-675-6622 extension 4866, fax at 416-675-4708 or email at healthandsafety@humber.ca if notified of an injury that is or could be classified as a ‘critical injury.

5. What to do if a Student is Injured/Ill During an Unpaid Work Placement

5.1 Incidient Response and Reporting Procedures

1. Any student experiencing an injury/illness as a result of a work placement incident must seek appropriate medical attention as required (e.g. hospital emergency department, placement employer's health clinic, outside clinic, family physician).

2. The student is required to follow the injury/illness response and reporting process of his/her Placement Employer.

3. The student must also immediately report the injury/illness to his/her Placement Supervisor and Humber Placement Coordinator.

4.The student must complete the ‘Student Placement Incident Report’ (Appendix E) in collaboration with the Placement Supervisor.

5. The student must fax the completed Incident Report within 24 hours of the incident to:

(a) the Humber Health Centre at 416-675-6320, and

(b) the Humber Placement Coordinator.

6. Upon receiving the Incident Report, the Health Centre will fax a copy of the report to Health and Safety Services at 416-675-4708.

7. The Health Centre will review the Incident Report and contact the student to follow up with the incident, if required.

8. The Humber Placement Coordinator will ensure that the Postsecondary Student Unpaid Work Placement Workplace Insurance Claim form is completed and sent to Health and Safety Services within 24 hours of the incident, as follows: 

(a) Access the blank online form, Postsecondary Student Unpaid Work Placement Insurance Claim Form from the MTCU website at www.tcu.gov.on.ca/pepg/publications/placement.html.

(b) Ensure the form is completed and signed by all three parties (Student, Placement Supervisor and Placement Coordinator on behalf of Humber), and

(c) Provide the completed form to Health and Safety Services via fax 416-675-4708 or by email to healthandsafety@humber.ca

9. Humber’s Placement Coordinator will provide Health and Safety Services with the following document within 24 hours of the incident, depending on the Placement Employer’s insurance coverage:

(a) Where WSIB insurance applies, a copy of the Placement Employer's completed portion of the 'Letter of Authorization to Represent Employer.' Proceed to Section 11 below.

(b) Where ACE INA insurance applies, Health and Saftey Services will orvide the ACE-INA claim forms to the students. Proceed to Section 12 below.

10. Health and Safety Services will review all injury-related reports and documents, and will initiate external reporting processes as required.

11. Reporting Process: WSIB Insurance Coverage

(a) Health and Safety Services will complete WSIB Form 7 within three days of learning of an unpaid placement-related injury or illness.

(b) Health and Safety Services will forward the completed WSIB Form 7, Postsecondary Student Unpaid Work Placement Workplace Insurance Claim form and the Letter of Authorization to Represent Employer form to the WSIB, MTCU and the Student Trainee no later than seven business days of learning of a placement-related injury or illness.

(c) Health and Safety Services will act as the central point of contact for Humber, between the Humber Placement Coordinator, the WSIB and the MTCU on matters related to the claim. The WSIB will also contact the student directly regarding his or her claim.

(d) The student is responsible for providing ongoing communication with the Placement Supervisor, Humber Placement Coordinator, Health and Safety Services and the WSIB regarding his or her claim.

12. Reporting Process: Private Insurance Coverage

(a) The student must complete and submit the ACE-INA forms directly to ACE-INA with a copy to Health and Safety Services. ACE-INA requires the initial claim to be made within the 30-day period following the accident.

(b) Health and Safety Services will forward copies of the Postsecondary Student Unpaid Work Placement Workplace Insurance Claim form and the ACE-INA forms to the MTCU.

(c) Health and Safety Services will act as a central point of contact for Humber with the MTCU on matters related to the claim. The student will communicate directly with ACE-INA regarding his or her claim.

(d) The student is responsible for providing ongoing communication with the Placement Supervisor, the Humber Placement Coordinator, Health and Safety Services and ACE-INA regarding his or her claim.

5.2 Summary of Documents Required for Filing a Claim 

5.2.1 WSIB Claims

• Student Placement Injury Report (Appendix E)
• Postsecondary Student Unpaid Work Placement Workplace Insurance Claim Form (refer to Appendix F for a scanned copy)
• Letter of Authorization to Represent Employer (Appendix G)
• WSIB Form 7

5.2.2 ACE-INA Claims

• Student Placemennt Injury Report (Appendix E)
• Postsecondary Student Unpaid Work Placement Workplace Insurance Claim Form (refer to Appendix F for a scanned copy)
• ACE–INA Claim Form

5.3 Reporting Timelines

5.3.1 Reports to the WSIB must be completed within 3 days and submitted within 7 days of learning of the incident. There are fines imposed for late reporting to the WSIB.  Notifying Health and Safety Services within 24 hours of learning of an incident will allow time to gather all of the required information, while still meeting the WSIB timelines.

5.3.2 ACE-INA requires that claims be made within 30 days of the incident occurrence. The contact information for ACE-INA is located on their forms.

5.4 Letter of Authorization to Represent Employer  

The Workplace Safety & Insurance Act (1997) governs the WSIB insurance system between employers and workers. The ‘employer’ of a student during the course of their unpaid work experience is the employer for which the student is performing work. However, in the event of an accident, because unpaid student placements are insured through the MTCU, Humber must assume the role of the employer for the purpose of administering the claim. Health and Safety Services communicates authorization to assume the role of the employer to the WSIB, through the completed ’Letter of Authorization to Represent Employer’ (Appendix G).

6. ACE-INA Data Collection 

For the purposes of determining private insurance premiums, information regarding student unpaid work placements at placement employers without WSIB coverage must be provided to the MTCU three times annually. Health and Safety Services provides a report to the MTCU with the requested information identifying the program, total hours of the unpaid work placement, number of students (grant eligible versus visa) and the application industry. At the end of each semester, Health and Safety Services will contact each academic school to provide this information. See Appendix H for a sample of the ACE–INA Insurance Statistics form.

7. Return to Work Process for Ill/Injured Students

Health and Safety Services will be responsible for maintaining contact with the Student Trainee, the Humber Placement Coordinator and the WSIB to ensure the availabilty of timely information relating to a Student Trainee's restrictions and the student's ability to safely resume the placement with the Placement Employer.

The Humber Placement Coordinator, in consultation with Health and Safety Services, will review the Student Trainee’s restrictions and any required accommodations. The Humber Placement Coordinator will contact the Placement Supervisor to discuss appropriate accommodations and modifications to the program, where required.

The Student Trainee has the option of sending medical documentation directlty to Health and Safety Services; all such documentation will be stored within Human Resources and treated in accordance with policy provisions for confidentiality.

8. Forms

Appendix A – Student Declaration of Understanding

Appendix B – Letter to Placement Employer

Appendic C – Template – Listing of Multiple Student Trainees at Single Placement Employer

Appendix D – Student Work Placement Safety Checklist

Appendix E – Student Placement Incident Report

Appendix F – Postsecondary Student Unpaid Work Placement Workplace Insurance Claim

Appendix G – Letter of Authorization to Act on Behalf of the Employer

Appendix H – Sample – MTCU ACE-INA Insurance Statistics Form