Targeted Provision - Risk Assessment Policy

1. Introduction

Targeted Provision (TP) is focused solely on providing the highest quality education and support whilst creating the best possible outcomes for the high acuity Children and Young People (CYP) in the SEN/Care system.

This policy should be read alongside the Health and Safety Policy and the Safeguarding and Child Protection Policy.

Providing educational provisions for such challenging CYP creates significant hazards and requires specific control measures, including any lone working arrangements. We therefore see it as a priority to ensure we have thorough risk management processes in place from the outset. All our tutors are directed to familiarise themselves with this policy as part of their journey through Safer Recruitment.

We take the health and safety of our staff and tutors extremely seriously and are guided by advice from the HSE and the Law. We are guided by the following pieces of legislation:

• The Health and Safety at Work etc Act 1974 (HSW Act)
  Employers have a legal duty under this Act to ensure, so far as it is reasonably practicable, the health, safety and welfare at work of their employees.

• The Management of Health and Safety at Work Regulations 1999
  Employers must consider the risks to employees (including the risk of reasonably foreseeable violence); decide how significant these risks are; decide what to do to prevent or control the risks; and develop a clear management plan to achieve this.

• The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)
  Employers must notify their enforcing authority in the event of an accident at work to any employee resulting in death, specified injury, or incapacity for normal work for seven or more days. This includes any act of non-consensual physical violence done to a person at work. More information is available at the HSE RIDDOR pages.

With respect to RIDDOR reporting:

As per guidance from the HSE, if you are working in someone else’s work premises and suffer either a specified injury or an over-seven-day injury, then the person in control of the premises will be responsible for reporting under RIDDOR, so, where possible, you should make sure they know about it.

If there is a reportable accident while you are working on your own premises or in domestic premises, or if a doctor tells you that you have a work-related disease or condition, then you need to report it via an accident report.

2. Summary of the reasonable steps we take to protect tutors and CYP

The below is not an exhaustive list of our attitudes to risk. Risks to tutors and CYP can emerge from a variety of places and present themselves in a variety of ways. We ensure that we always do all we reasonably can to request profiles of the CYP we work with from those who commission us for support. In addition to the above we:

Produce, monitor, update and share this Risk Assessment Policy.

Collect risks associated with CYP at the point of referral.

Share all known risks with the tutor before any provision commences.

Provide an escalating level of risk management (Appendix A) for the CYP and the tutor, for every referral, as part of their contract for services.

Highlight the steps we have taken to protect tutors as part of their contract for services.

Highlight the steps we expect out tutors to take to ensure their own safety.

Ask tutors about risks and risk management as part of their Safer Recruitment process, including asking them if they are willing to work as a tutor with the increased risk surrounding some CYP in this space.

Conduct a bi-annual Risk Assessment Audit of our approach to risk management and implement improvements on the back of these audits.

3. Aims and Objectives

This policy aims to ensure that all workers understand the process of risk management and how it can be integrated into effective supervision practices.

This policy and its contents are one of the several reasonable steps we take to protect the health and safety of teachers/tutors and CYP.

We have specific objectives in place to help protect those involved in our provisions, which include:

• Ensuring there are sufficient systems in place to access and disseminate all risk management documentation relating to each individual young person.

• Ensuring that everyone understands their responsibilities regarding how they manage their own safety when working alongside CYP.

• Ensuring that our tutors fully understand their responsibilities regarding how they manage the safety of the CYP they work with.

4. Applying the Policy: Dissemination of information

The referral procedures agreed with commissioning bodies, including school and Local Authorities, emphasise the importance of sharing information about each individual young person. The documentation we require, if available, at the point of referral will include:

• Young Person Risk Assessments (YPRA).

• Positive Behaviour Support Plans (PBSP).

• Education, Health and Care Plans (EHCP).

• Personal Education Plans (PEP).

• Any Therapeutic Assessments Inc. CAMHS reports.

• Any accident or medical reports.

• Any specific additional risk factors e.g. fire starter, RSO, persistent allegations against staff, sexualised behaviours, physically challenging behaviours, gangs, weapons.

5. Steps taken to establish additional risks

We always ask about specific risks surrounding the CYP in question and we do our best to ensure that we receive full disclosure about these risks.

If any commissioning body makes us aware of risks surrounding the CYP, and, for whatever reason, refuses or fails to supply this risk information, we will not go ahead with the referral.

Once collated, all risk management information will be shared with individual tutors prior to them attending any placement. This will be shared in writing as part of their Contract for Services

In a reciprocal manner, if requested, we will share all pertinent information regarding our tutors with the placement including:

• Up to date enhanced DBS certificate.

• References from previous clients/services.

• Personal contact information

6. Applying the Policy: Tutor Safety

As discussed in point (3) above, tutors are provided with any identified risks prior to the commencement of any referral for a CYP.

Tutors are directed to:

• Familiarise themselves with all documentation relating to each young person they are instructed to support.

• At no point undertake lone working with any young people. In practice, this means that tutors should always ensure that there is a responsible adult in the immediate vicinity (remain in direct verbal contact with supporting adults throughout each and every session). This individual will also be responsible for administering any regular or emergency medication of first aid requirements which may be required/arise during the tutoring session.

• At no point engage in any physical interventions. This remains the responsibility of the additional responsible adult should a need occur.

• Medical Emergencies will be dealt with by the additional responsible adult as above. If a situation occurs where this additional responsible adult is the subject of a medical emergency out tutors will:

  • Call the emergency services.

  • Call for support from other adults in the vicinity.

  • Ensure their student is supported at all times by telling another adult they have been left exposed by the emergency.

  • Simply record in their session report that the session had been disrupted by a medical emergency.

  • Raise a safeguarding concern where the details can be recorded securely.

  • Complete an accident report.

• Familiarise themselves with existing risk management provisions within the placement including any site specific risk assessments and procedures relating to fire evacuation protocols, as they will be subject to these controls while working with CYP.

As set out in the tutors contract for flexible educational support services, - which is issued to all tutors at the beginning of their referral, we recommend they undertake a thorough familiarisation session with supporting adults on arrival at any placement to identify any specific risks within the tuition environment. Guidance is available here.

7. Reporting risks to safety

Tutors must report to both their supporting adults within the placement and to our Designated Safeguarding Lead (DSL), Emma Stanway, if:

• They have concerns regarding the safety of CYP*.

• They have concerns regarding their own safety.

• Become aware of any information disclosed by the CYP which places anyone at risk.

• Witness behaviours of concern that places anyone at risk.

• Is the subject of or witnesses to any accidents or anticipates an accident.

*The reporting of Safeguarding Concerns is covered at length in our Safeguarding and Child Protection policy.

If, after reporting to supporting adults, a tutor considers the placement to be unsafe to either themselves or the young person they are supporting, they are to retire from the situation and report directly to the DSL. At no point will a tutor retire from a placement without notifying the supporting adults within the placement.

If an accident occurs resulting in injury to the tutor, CYP or supporting adult it must be reported using our online form within 24 hrs of the incident. If a tutor anticipates an accident due to perceived negligence or inadequate safety, they must notify their contact at TP as soon as possible so the accident can be prevented.

The tutor who reported the accident has to cooperate with TP if called upon as part of any resultant investigation.

As a general rule, the tutor must provide information in the incident report as accurately as possible on the following:

• The place of the accident

• The date and time of the accident

• The people involved or injured

• Their position or involvement in the accident

• Their actions immediately after the accident

8. Off-Site Risk Assessments

Prior to any tutor commencing a placement, referral procedures will identify where tutoring will take place and who the supporting adults will be. All pre-existing risk management procedures produced by the placement will apply as long as tutoring takes place on this identified site and supporting adults remain in attendance.

Should a tutor need to arrange any off site activities as part of the agreed provision and directly linked to the desired outcomes of the intervention e.g. socialisation in public spaces or fieldwork as part of subject specifications, then the following procedure should be followed:

• The tutor, in consultation with the appropriate supporting adults from the home, should complete the off-site risk assessment document provided to them via their tutor portal.

• Once completed, this document should be automatically submitted to our SEND support team/safeguarding team. This needs to be received a minimum of two working days prior to any planned activity taking place.

• The submitted risk assessment will be assessed by the SEND support owner who will consult with the H&S officer if necessary.

• Acceptable risk assessments will be converted to PDF and returned to the tutor by email along with a personalised parental consent form.

• Off-site activities must not take place until all documentation and due processes have been completed:

  • The tutor has a copy of an acceptable risk assessment which parents/carers have seen and agreed.

  • There is a copy of the parental consent form on file with TP.

  • The appropriate additional adults have been identified and agreed with the parents/carers.

  • The CYP is fully prepared for the activity, appropriately dressed and happy to continue.

On the rare occasions when previously unidentified risks become apparent, the tutor and supporting adult may need to undertake a dynamic risk assessment to manage the new situation. If a dynamic risk assessment has taken place, a formal written risk assessment record must be made as soon as is reasonably practicable after the event and shared with the SEND support owner, parents/carers and TP’s DSL.

Once an activity is complete it is good practice to evaluate the effectiveness of the risk management processes and update if necessary. Each activity should be regarded as a separate event; recycling existing documentation without review is unacceptable.

Once a risk assessment is obsolete it must be archived for a minimum of 5 years.

9. Appendix A

9.1. Individual Support Plan (ISP)

We make every reasonable effort to collect as much information as possible relating to the individual pupils at the point of referral. Each referral will be risk assessed based on the information provided by the commissioner. This information will be reviewed and all identifiable risks identified.

Based on the level of risk identified through this review process we will implement an escalating level of risk management:

Collect all relevant information and share it securely with the tutor.

Highlight to the tutor any areas of concern to be aware of.

Open an Individual Support Plan recording:

• all identified triggers/presenting behaviours.

• recommended proactive and reactive control measures to reduce the risk.

• details of agreed exit strategy if required.

• any additional comments.

• risk rating

• commencement and review dates.

Each ‘risk’ is assessed to provide a ‘risk level’ and both proactive and reactive control measures are identified with a view to reducing the ‘risk’ to a minimum.

Assessing the ‘risks’ posed by an individual pupil needs to be supported by full disclosure of information from commissioners and supporting adults/carers/parents. It is not necessarily a difficult or technical process. In most cases adults with existing knowledge of the YP will already be aware of the main risks and will know the appropriate measures to control them.

Risk assessment and management is particularly important for pupils with SEMH and ASC. Challenging or concerning behaviours are often unforeseeable, it may be difficult to predict exactly what the driving emotions are and therefore when they will occur, or the degree of challenge/concern they will pose. The measures established for managing identified risks should assist tutors in their daily work with pupils.

There are a number of possible outcomes from adopting risk reduction strategies.

• limit the seriousness of the risk to a tolerable level

• reduce the probability of the risk

• eliminate the risk completely

Risk management procedures for YP with high risk levels will be shared with parents/carers, commissioners and other appropriate stakeholders.

9.2. Calculating the Level of Risk

Once the ‘Risk’ has been identified then the ‘Level of Risk’ should be determined. This is calculated by scoring the

‘Probable frequency’ of risk (1: Rare, 2: Unlikely, 3: Possible, 4: Likely and 5: Almost certain) and the ‘Severity’ (1: Insignificant, 2: Minor, 3: Moderate, 4: Major and 5: Catastrophic). Multiplying the two scores together produces an overall score which identifies the level of risk involved (1-25).

 

The tutor will also need to assess the risk as either Accidental/Unintentional or Deliberate.

9.3. Evidencing the Risk

There are many ways in which potential risks become known; observed, reported verbally or documented. Tutors need to be able to access referral documentation and existing supporting adults to allow all previously known risks to be assessed.

9.4. Guidance for completing Individual Support Plans (ISP)

9.5. Known Triggers/Presenting Behaviours (What kind of things lead to a loss of control?)

This section should outline what prompts an escalation in the YP’s behaviour. Any known antecedent behaviours should be recorded.

It is important to note that there may be no identifiable triggers or antecedents and this should be included in this section if this is the case.

9.6. Control Measures to reduce risk

Risks are mitigated through the use of control measures (de-escalation strategies).

It is also important to remember to include both ‘proactive’ and ‘reactive’ control measures in this section.

Below are examples of Risks and possible Control Measures (‘proactive’ and ‘reactive’).

9.7. Proactive Control Measures to reduce the risk:

Risk: Violence & Aggression

• No lone working

• Close contact with appropriate supporting adults at all time.

• Exit strategy agreed with appropriate supporting adults.

• Reduced unstructured time to ensure the Young Person is actively engaged, reducing the opportunity to become bored, anxious or distressed.

• Awareness of Positive Behaviour Support strategies in terms of proactive, reactive interventions and triggers.

9.8. Reactive Control Measures to reduce the risk:

• Implement an agreed exit strategy.

• Consequences to be put in place for instances of physical aggression. These will be implemented consistently by appropriate supporting adults.

• Restorative practice sessions to be completed following all instances of physical aggression.

• Use of landline or mobile telephones to summon emergency services if required.

9.9. Reviewing Requirements

Risk Assessments need to be reviewed dynamically in response to any incidents and need to include any new or increased risks and the appropriate control measures.

In the absence of any further incidents ISPs should be reviewed/updated every six weeks as a minimum.