Off-Campus Activity Safety Policy | University Secretariat and Legal Counsel

Category: Administration

Approval: Senior Leadership Team

Responsibility: VP, Finance and Administration

Current Approval: January, 2023

Previous Approval: May 2010, May 2009, May 2008, May 2006, December 2004, March 2004

Purpose

The safety of all Participants in Off-Campus Activities is of paramount importance to the university. To meet legal and moral obligations, with respect to the health and safety of Queen’s University Members participating in university-sanctioned Off-Campus Activities, the university strives to impart awareness of safety issues to the members of its community. The university also seeks to establish mechanisms for University Members to access guidance and support while planning and/or participating in Off-Campus Activities. Furthermore, the university has a responsibility to manage risks associated with its operations. The Off-Campus Activity Safety Policy (OCASP) and the accompanying Procedures and Guideline establish a framework for risk assessment, planning, preparation and support for university-organized and university-sanctioned Off-Campus Activities.

Accompanying Procedures and Guideline:

The following procedures and guidelines support the implementation of the Off-Campus Activity Safety Policy:

Related policies, procedures and guidelines are listed at the end of this policy and in the accompanying procedures and guideline

Scope

The Policy covers any Off-Campus Activity involving one or more University Members that is supported or expressly approved by an employee of the university (or an individual acting under the authorization of, or as a delegate of, a university employee or committee) during the course of their duties. A commitment of university resources (physical or financial, including research funding) signifies university support of an Off-Campus Activity and brings the activity under the scope of this Policy. Off-Campus Activities include:

Field research conducted by Participants (including travel to and from the site(s) of the field research), provided that the research falls within the Queen’s employment responsibilities or academic program of the Participant
All Off-Campus Activities that are part of Queen’s University academic (for-credit) courses and programs (including travel to and from the site(s) of the activity)
Travel by faculty, staff, post-doctoral fellows and graduate and undergraduate students on Queen’s University-related business or activities (e.g., conferences, academic or administrative meetings, recruitment fairs)
Road trips by Queen’s Varsity athletic teams and university-supported athletic clubs, and all off-campus athletic activities involving such groups except athletic events sanctioned by Ontario University Athletics (OUA), U Sports, and/or similar such state, conference and/or national post-secondary institutions in the United States with comparable standards (e.g. NCAA, NAIA, NJCAA)
Other extra-curricular Off-Campus Activities that are organized, sanctioned or funded in whole or in part by the university, (e.g., Queen’s Off-Road Robotics Initiative, School of Business Case Competitions, or Queen’s Solar Design Team)

This Policy does not cover activities over which the university exercises no control and for which it can therefore take no responsibility. Specifically, among others, this Policy does not cover:

External activities (including consulting) undertaken by faculty, post-doctoral fellows, staff or students that are not part of the individual’s employment responsibilities or academic program at Queen’s
Activities organized exclusively by students or student groups (including but not limited to the AMS, SGPS, faculty societies and student clubs) without expressed approval, sanction, or funding from the university
Activities that have their own risk management process which has been approved by the Department of Environmental Health and Safety (e.g., student residence activities expressly approved by the university, and organized under the auspices of The Residence Council, and activities organized by Bader College at Herstmonceux Castle)
Travel or activities of any person who is not a University Member or Authorized Volunteer (e.g., a person accompanying a University Member traveling to attend a conference would not be considered an Authorized Volunteer because the accompanying individual is not traveling for the purpose of participating in the conference)

This policy does not cover travel or attendance by any individual, who is not a University Member, for events organized through the Office of Advancement, faculty-based advancement teams, the Queen’s University Alumni Association or any of its Branches or Chapters.

If an individual is unclear if an activity or activity location is covered under this Policy, they should consult with the Department of Environmental Health and Safety.

Policy Statement

All university-organized and sanctioned Off-Campus Activities must be evaluated based on the risk definitions and processes outlined in the Risk Assessment Procedure. This assessment must be completed before the Off-Campus Activity takes place, so that appropriate advanced planning, preparation, documentation and training are completed, foreseeable risks are appropriately managed, and any required approvals are obtained.

A record must be created in the Safe Travel Activity Registration Tool (START) for any Off-Campus Activity that includes undergraduate students (i.e., students in first-entry baccalaureate or professional (J.D., MD, B.Ed.) programs), graduate students or post-doctoral fellows as Participants. See Low Risk and High Risk Off-Campus Activity Procedures

Staff and faculty are required to complete a record in START for all High Risk Off-Campus Activities.

Staff and faculty are strongly encouraged but not required to complete a record for Low Risk Off-Campus Activities in START, unless they are the Activity Planner for a Low Risk Off-Campus Activity that includes undergraduate students (i.e., students in first-entry baccalaureate or professional (J.D., MD, B.Ed.) programs),graduate students or post-doctoral fellows as Participants. Should any assistance be needed when off-campus, the information in the OCASP records is used to provide support. Staff and faculty who do not submit an OCASP record for their Low Risk Off-Campus Activity are required to provide details of their travel (dates, locations and emergency contact information) to their department/unit. In lieu of tracking travel information, the department/unit head can direct staff and faculty to submit a record for all Low-Risk Off-Campus Activities.

All Participants in an Off-Campus Activity are required to comply with reporting requirements, regardless of whether or not a record has been created in START See Reporting Procedure.

Exceptions: Low risk off-campus activities conducted within the Kingston area do not require a record in START (or with the participant’s department). There are other circumstances where low risk activities would not require a record in START. Refer to the Low Risk Off-Campus Activity Frequently Asked Questions (FAQs). If you have additional concerns or questions please email ocasp@queensu.ca

Responsibilities

Department of Environmental Health and Safety

Educate University Members about this Policy and the accompanying Procedures and Guideline
Provide advice and guidance to support the implementation of this Policy
Provide general training to orient Participants to Off-Campus Activities. (Activity-specific training is the responsibility of the Person in Authority and the Activity Planner)
Manage the provision of an Emergency Support Program for Participants
Disseminate information about hazards and/or health and safety incidents that may be relevant to Off-Campus Activities that are in progress and/or to future Off-Campus Activities
Provide guidance to Activity Planners, Persons in Authority, and Participants on the implications of new information relevant to the activity and/or the location of the activity (e.g., travel advisories) and/or on incidents that occur during an Off-Campus Activity
Withhold any risk assessment or safety planning record approval when all hazards have not been considered or appropriately mitigated, and/or new information requires further assessment by the Activity Planner and the Person in Authority
Provide advice and guidance to assist Deans (or their delegates) and/or Persons in Authority in meeting their responsibility to address non-compliance with this Policy
Investigate health and safety incidents related to Off-Campus Activities and manage any required external reporting
Manage data and internal reporting related to this Policy
Modify the Procedures and/or Guideline as needed. In an emergency situation, this may be done outside of the normal policy approval process as directed by the Senior Leadership Team (SLT).

Deans/Delegates

Educate all Departments/Units under their supervision about the provisions of this Policy and the accompanying Procedures and Guideline, including roles and responsibilities.
Impose an appropriate level of sanction on any member of a Department/Unit under their supervision who does not comply with this Policy and/or the accompanying Procedures and Guideline.

Department/Unit Head, Program Director or anyone acting in the role of a Person in Authority

Comply with the provision of this Policy and the accompanying Procedures and Guideline
Educate all members of Departments/Units under their supervision about the provisions of this Policy and the accompanying Procedures and Guideline, including roles and responsibilities
Impose an appropriate level of sanction on any member of a Department/Unit under their supervision who does not comply with this Policy and/or the accompanying Procedures and Guideline
Approve the level of risk assigned to the Off-Campus Activity (See Risk Assessment Procedure)
Where the Department/Unit does not require staff or faculty to register Low Risk Off-Campus activities in START, the Department/Unit must maintain a list of these Participants. The list must include activity dates, locations and emergency contact information. Upon request, the Department/Unit must provide this list to Department of Environmental Health and Safety
Approve safety planning records for High Risk Off-Campus Activities. (See Risk Assessment and High Risk Off-Campus Activity Procedures) As part of this process, assess the appropriateness and completeness of the activity-specific training or certification (e.g., wilderness first aid) proposed by the Activity Planner
Identify any Department/Unit-level training/certification required, in addition to the general training provided by the Department of Environmental Health and Safety and the training and/or certification proposed by the Activity Planner
Determine, in consultation with the Department of Environmental Health and Safety, if an Off-Campus Activity should be cancelled or terminated, when continuing would entail Unmanageable Risk (See Risk Assessment and Reporting Procedures)
Make reasonable efforts to accommodate a student’s need to find alternate ways to complete a program of off-campus study (e.g., exchange or study-abroad program, placement or practicum) or field research, should the student be required to change their plans due to an incident and/or a change in the risk of the activity and/or activity location. Accommodation may include placement at an alternate host institution, granting an extension, identifying alternate ways to complete a research project
Consult with the Department of Environmental Health and Safety should any individual decide to engage in an Off-Campus Activity that has not been approved or is cancelled or terminated because it has been deemed to entail Unmanageable Risk
Require any individual who decides to engage in an Off-Campus Activity that has not been approved because it has been deemed to entail Unmanageable Risk or has been cancelled or terminated due to Unmanageable Risk to sign and submit a waiver provided by Queen’s Insurance and Risk Management Office (insurance@queensu.ca). If any individual decides to engage in the Off-Campus Activity where the risk has been determined to be Unmanageable they do so at their own risk and assume all liability.
Complete required reporting. (See Reporting Procedure)
Disseminate information within the Departments/Units about hazards, risks, and risk mitigation plans to inform planning of Off-Campus Activities

Activity Planners

Comply with the provisions of this Policy and the accompanying Procedures and Guideline
Consult and seek the expertise of others so that the appropriate level of risk is assigned to the Off-Campus Activity and that risk(s) associated with the activity are appropriately identified and addressed (See Risk Assessment and High Risk Off-Campus Activity Procedures)
Complete any records required based on the result of the risk assessment (See Low and High Risk Off-Campus Activity Procedures)
Identify any activity-specific additional training or certification (e.g., wilderness first id), not already provided by the Department of Environmental Health and Safety and/or training/certification required by the Department/Unit. For High Risk Off-Campus Activities, training and/or certification must reflect and support the risk management plan identified in the safety planning record (See High Risk Off-Campus Activity Procedure).
Educate Participants for whom they are responsible about the provisions of this Policy and the accompanying Procedures and Guideline, including roles and responsibilities
Brief Participants for whom they are responsible, prior to the start of any Off-Campus Activity, so that Participants are appropriately prepared and able to conduct themselves in a safe manner while engaging in the Off-Campus Activity
Validate that Participants have completed any required consent processes, training and/or certification (e.g., wilderness first aid) before the start of any Off-Campus Activity
Review the Insurance and Risk Management Office Website to ensure they and/or Participants for whom they are responsible have the appropriate coverage, including health coverage plans (i.e., through HR, AMS or SGPS) and coverage for university-owned, private and/or rental property/vehicles.
Obtain the appropriate insurance coverage as well as the appropriate Visa(s) and immunizations (if applicable)
Complete required reporting (See Reporting Procedure)

Participants

Comply with the provisions of this Policy and the accompanying Procedures and Guideline
Complete all pre-activity requirements. These can include immunizations, trainings, orientations/briefings, certifications (e.g., scuba diving, First Aid) and any consent process required under the Policy or by the Department/Unit.
Review the Insurance and Risk Management Office Website to ensure they have the appropriate coverage, including health coverage plans (i.e., through HR, AMS or SGPS) and coverage for university-owned, private and/or rental property/vehicles.
Obtain the appropriate insurance coverage as well as the appropriate Visa(s) and immunizations (if applicable)
Identify to the Activity Planner any needs requiring accommodation so that these may be addressed in the planning process
Prepare self in advance of any Off-Campus Activity and conduct self in a safe manner while engaging in Off-Campus Activities
Follow the safety procedures established by the Activity Planner, including using the appropriate protective equipment.
Complete required reporting, particularly in situations where the health and safety of any Participant could be impacted (See Reporting Procedure).

Internal Audit

Perform regular audits throughout the year of employee travel claims to assess compliance with the Policy and supporting Procedures and Guideline, and report instance of non-compliance to Department of Environmental Health and Safety

Definitions: Off-Campus Activity

Off-Campus Activity: Any field research or an academic/extra-curricular/administrative activity that takes place beyond the boundaries of the Activity Planner’s or Participant’s primary Queen’s location. Queen’s locations include all Queen’s Campuses in Kingston, Ontario and other locations owned or leased by Queen’s University (e.g., SNOLAB, Smith School of Business in Toronto), and locations that are approved under a Remote Work Agreement.

Definitions: Roles

Activity Planner: The individual with direct responsibility for planning or leading an Off-Campus Activity. Examples of Activity Planners are course instructors, team coaches, a Principal Investigator (PI) who has direct responsibility for a field research project or activity, or a graduate student or post-doctoral fellow who plans and executes a field, thesis or post-doctoral research project or activity and/or a project carried out under a research or service agreement. The Activity Planner may also be a Participant (see definition below) and must fulfill the responsibilities of both roles.

Authorized Volunteer: An individual who is not a University Member but who participates voluntarily in an Off-Campus Activity with the approval of the Activity Planner and the Person in Authority.

Participant: Any University Member and/or Authorized Volunteer who takes part in an Off-Campus Activity.

Person in Authority: The individual responsible for approving the Off-Campus Activity under this Policy. In most cases, this will be the Department/Unit Head or Program Director to whom the Activity Planner reports. Where a Department/Unit Head, Program Director, Dean or Vice-Principal is the Activity Planner, the Person in Authority would be their supervisor (Dean, Vice-Principal or Principal). There are three exceptions:

For off-campus field-study trips by students at the Bader College, the Executive Director of the Centre is the Person in Authority
For undergraduate academic exchanges, activities undertaken by Queen's Project on International Development (QPID), Queen’s Heath Outreach (QHO) and Mitacs Research Awards that involve international travel, the Director of Environmental Health and Safety or their designate is the Person in Authority.
For student-organized, extra-curricular activity sanctioned or funded by the university, the university official who provides the sanction or authorizes the financial contribution assumes the responsibility of the Person in Authority

University Members: All undergraduate and graduate students, post-doctoral fellows, faculty and staff.

Definition: Unmanageable Risk

An activity is deemed to have an Unmanageable Risk level when sustainable mitigation strategies that would bring the risk level to a manageable threshold cannot be achieved. Examples of activities where it may not be possible to put in place sustainable mitigation strategies include:

Travel to active war zones
Travel to an area where there is an acute public health event (e.g., Ebola outbreak)
Solitary field research or travel in remote or hazardous areas (considering access to emergency or medical services and/or phone/911 coverage)
Travel to an area where a recent natural disaster has caused infrastructure damage and the provision of basic services continues to be disrupted. This includes locations where the risk of re-occurrence of the event that caused the disaster remains high (i.e. aftershocks, additional avalanches, etc.)
Travel to a location where a travel and/or health advisory to avoid all travel has been issued by external agencies such as Global Affairs Canada (GAC), Health Canada, World Health Organization (WHO), International SOS, etc.
An activity where the amount of training required or the extent or cost of the safety precautions necessary to overcome the risks associated with a group’s size or the experience of its members is prohibitive.

Instructions for assessing the effectiveness of the mitigations and the resulting risk level is outlined in the Risk Assessment Procedure

Contact Officer: Director, Environmental Health and Safety

Date for Next Review: January, 2028

Related Policies, Procedures and Guidelines:

Risk Assessment Procedure

Low Risk Off-Campus Activity Procedure

High Risk Off-Campus Activity Procedure

Reporting Procedure

Guideline - Support While Travelling

Accommodation of Disabilities in the Workplace Policy

Academic Accommodations for Students with Disabilities Policy

Health and Safety Management System

Policy Statement on Health and Safety