High Risk Off-Campus Activity Procedure | University Secretariat and Legal Counsel

Final Approval Body: Senior Leadership Team

Senior Administrative Position with Responsibility for Procedure: VP, Finance and Administration

Date Initially Approved: January, 2023

Purpose

This Procedure guides you in completing the actions required under the Off-Campus Activity Safety Policy for a High Risk Off-Campus Activity. This includes the steps required to set up a High Risk Off-Campus Safety Planning Record using the Safe Travel Activity Registration Tool (START).

Prior to starting to create your Safety Planning Record in START, it is recommended that you consult resources to help you identify hazards relevant to the location of your activity and/or the planned activity, including:

Your faculty/department
Department of Environment Health and Safety
Global Affairs Canada (GAC) website
International SOS (ISOS)

Accompanying Procedures and Guidelines

In addition to this High Risk Off-Campus Activity Procedure, implementation of the Off-Campus Activity Policy is supported by the following procedures and guidelines. It is recommended that you review these documents to ensure you understand the steps required to comply with the Policy:

Supporting resources can be found on the OCASP Website.

Related Policies, Procedures and Guidelines are listed at the end of this procedure.

Procedure

The steps to determine risk level are outlined in the Risk Assessment Procedure.

The following steps are required for all High Risk Off-Campus Activities. All steps are completed by the Activity Planner except for Steps Four, Six, Eight and Ten.

Step Six must be completed by Participants who the Activity Planner includes in the Safety Planning Record in START (For example, the class members the Activity Planner adds to the Safety Planning Record for a class field trip).
Step Eight must be completed by both the Activity Planner and any Participants.
Step Four and Step Ten are the responsibility of the Person in Authority.

Links to supporting resources (e.g., Global Affairs Canada website, examples of Safety Planning Records) can be found on the OCASP Website.

Step 1: Create a Safety Planning Record in START

Who is Responsible: Activity Planner

Safety planning records are created online in START.
When creating a new High Risk Off-Campus Activity safety planning record, you can copy and modify a record you previously submitted.
If copying an existing safety planning record, you are responsible for ensuring all the information is current and relevant to the proposed Off-Campus Activity.
Safety planning records in START can be completed in stages before being submitted. This allows you to consult resources, should a question or concern arise while creating the record.
Prior to logging into START, gather the following information:
- Information if travelling domestically
  - Location of activity (geographical site, host institution, etc.)
  - Nearest city to activity location
  - Distance to nearest city (KM)
- Information required if travelling internationally
  - Citizenship under which you are travelling
  - Country of Activity
  - Any travel advisories for the country of activity from, for example, International SOS Members Portal or Global Affairs Canada (GAC)
  - Location of activity (geographical site, host institution, etc.)
  - Nearest city to activity location
  - Distance to nearest city (KM)
  - Passport number – while optional, it is recommended that you provide your passport number as this information can be useful to have on file, if you need support in an emergency
- Information required if planning a group activity
  - You will need to register Participants individually or select a class list through START.
  - If registering Participants individually, you will need to provide their names and emails.
  - If applicable, include the name(s) of any Activity Leader (s) who are supporting the Off-Campus Activity. You will need the following information for each Activity Leader: name, email, training/certifications (e.g., first aid).
- Itinerary
  - Start and end dates, mode of transportation (including flight/train number and/or car rental agency) and activity description for each travel step in your journey, including your return home.
- Risk Management Plan
  - In this section of your Safety Planning Record, you will be asked to identify the different hazards associated with your Off-Campus Activity, and how you will manage/mitigate each identified hazard (i.e., your risk management plan).
  - You must consider hazards specific to the activity (e.g., rock climbing, scuba diving, mountaineering, etc.), the location(s) of the activity(ies) and your mode of travel to the location (e.g., by ATV on trails).
  - For each hazard, you will be asked to Identify how this hazard is a risk to you and any Participants for whom you are responsible. You must consider harm across a range of dimensions (e.g., physical, financial, medical, property, etc.).
  - When preparing your risk management plan, include how you will manage emotional/ psychological distress, procedures for ensuring appropriate use of PPE equipment, processes to ensure Participants are appropriately prepared (e.g., training, certifications), and a plan for managing communication with Participants.
  - If you are travelling internationally, you will also be asked to consider hazards and risks related to your travel and activity outside of Canada. Specifically, you will be asked to comment on any hazards and risks for your host country(ies) using categories from the GAC (Global Affairs Canada) Travel Reports and Warnings. You should consult Global Affairs Canada (GAC) Travel Advisories and International SOS (ISOS) Members Portal travel reports. To access the ISOS portal, you will need to enter the Queen's ISOS membership number. You can find the ISOS membership number in START.
  - If you are travelling internationally, you should also assess the human rights and equity profile and cultural norms of your host country(ies) and any potential impact to yourself and/or any Participants for whom are you responsible.
- Supplementary Travel Insurance Provider
  - The name of your supplementary travel insurance provider such as, Manulife, Blue Cross, etc. DO NOT include UHIP or your Canadian provincial health insurance provider as they are your primary insurance.
- Immunizations
  - The types of any required immunizations (e.g., Yellow Fever).
- Disabilities, Special Needs, or Life-threatening Health Conditions
  - Provide the category of need/functional limitation (e.g., mobility, allergy, vision) and how the need will be considered and/or supported during the Off-Campus Activity.
- Your (Activity Planner) Emergency Contact Information
  - Additional Queen's University contacts.
  - Local emergency contact information at your activity site. If you are travelling internationally, you must provide phone numbers for each of your host country's equivalent[s] to our 911 system for emergency calls. Some countries have more than one emergency number, e.g., one for Fire, one for Police, a third for Ambulance.
  - Contact information for your host destination. This could include the host institution/hotel email, phone, social media, etc.
  - Two personal emergency contacts.
- Emergency Evacuation Plan
  - If an evacuation plan is required as part of your Off-Campus Activity, you will be asked to load a copy into your Safety Planning Record.

The level of detail included in your Safety Planning Record must be sufficient to demonstrate to the Person in Authority and external regulatory authorities, if applicable, that the hazards identified were adequately mitigated.

Step 2: Complete Pre-Departure Training

Who is Responsible: Activity Planner

You will be automatically directed to complete online training within START based on the type of travel and/or activity (e.g., international travel, field studies).
Undergraduate students will NOT be able to submit their Off-Campus Activity safety planning record until this training is complete.
Departments/Faculties may require you to complete certain training modules within START. You must check with the Person in Authority to determine if any of the modules are mandatory for you.
Complete any additional department- or faculty-specific orientation or training requirements. Please contact the Person in Authority for direction.

Step 3: Acknowledge Responsibilities Under the Policy

Who is Responsible: Activity Planner

As part of your Off-Campus Activity safety planning record, in START, you will be asked to confirm that you understand your responsibilities related to the Off-Campus Activity, including insurance, immunization, visas, risk assessment and management, monitoring travel advisories, and timely reporting of any incidents.

Step 4: Approve or Deny Planning Record for Off-Campus Activity

Who is Responsible: Person in Authority

Review the Safety Planning Record submitted by the Activity Planner in START.
As part of your review, you must assess the appropriateness of the training or certification (e.g., wilderness first-aid) proposed by the Activity Planner for managing or mitigating hazards and risks, and preparing Participants.
Approve the Safety Planning Record as submitted or ask the Activity Planner to revise and resubmit.
If the activity risk is determined to be unmanageable, direct the Activity Planner to cancel the Off-Campus Activity.

If an activity is not approved due to Unmanageable Risk

Reasonable efforts should be made 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 in a region.
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.
If this situation arises, consult the Department of Environmental Health and Safety.
Direct the individual to sign and submit a waiver provided by Queen’s Insurance and Risk Management Office (insurance@queensu.ca).

Step 5: Revise the Safety Planning Record if Required

Who is Responsible: Activity Planner

If required, and as directed by the Person in Authority, revise and re-submit the Safety Planning Record.

Step 6: Complete Participant Acceptance in START

Who is Responsible: Participant

START will automatically notify individuals by email when the Activity Planner has included them as a Participant in Safety Planning Record. The record identifies all the elements of the Off-Campus Activity in which you will be participating.
Participants are required to review and accept this Safety Planning Record in START.
Prior to logging into START to review the plan, gather the following information:
- Contact information for 2 personal emergency contacts.
- Information required if travelling internationally:
  - Citizenship related to country of activity
  - Citizenship under which you are travelling
  - Passport number – while optional, it is recommended that you provide your passport number as this information can be useful to have on file, if you need support in an emergency.
Participants will be asked to complete a consent in START that confirms they have familiarized themselves with and acknowledge the potential risks and their responsibilities related to the Off-Campus Activity.

Step 7: Complete Pre-Departure Activities

Who is Responsible: Activity Planner

Prepare and complete pre-departure orientations with any Participants you are responsible for. Orientations should reflect the nature of the activity and the experience of the participants.
Verify that all Participants have completed the Participant Acceptance and all required training, orientations, etc. have been completed/obtained.
Inform Participants that it is their responsibility to obtain appropriate insurance coverage as well as the appropriate Visa(s) and immunizations (if applicable).
Pre-arrange any special needs for yourself or participant(s) with disabilities, health needs, etc.
Review your reporting requirements and direct Participants to do the same. <<see Reporting Procedure>>.

Step 8: Ensure Appropriate Insurance Coverage

Who is Responsible: Activity Planner and Participants

Review the Insurance and Risk Management Office Website to ensure you 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).

Step 9: Report Any Change in Activity or Activity Location

Who is Responsible: Activity Planner

If there is any change to the activity and/or the location of the activity prior to departure or during the activity, you must consult with the Person in Authority and/or the Department of Environmental Health and Safety.
If required, you may need to submit a new Off-Campus Activity safety planning record, or, if the risk is found to be unmanageable, to cancel or terminate the Off-Campus Activity.

Step 10: If an Activity is Cancelled Due to Unmanageable Risk

Who is Responsible: Person in Authority

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.
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.
If this situation arises, consult the Department of Environmental Health and Safety.
Direct the individual to sign and submit a waiver provided by Queen’s Insurance and Risk Management Office (insurance@queensu.ca).

Definition: 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 Leader: Any individual(s) who, in addition the Activity Planner, have responsibility for leading or co-leading the Off-Campus Activity.

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 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 fulfil 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 International Study Centre, 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, staff, and faculty.

Definitions: Risk

Hazard: A situation, circumstance, condition, substance, behaviour, or practice with the potential to cause an injury, illness, or property damage.

High Risk: an activity is deemed to be high risk if it has the potential to expose participants to hazards that are significantly greater than those likely to be encountered in their everyday lives. Potential risks may be associated with the activity itself, with ancillary activities such as travel to the site, and/or environmental, health, safety or security risks that are characteristic of the location. Examples include:

research or study at industrial or medical facilities which pose health or safety risks (e.g., mine site, corrections facility, manufacturing facility)
Working/traveling in remote regions (considering limited access to medical services and/or phone/911 coverage) or regions natural hazards (i.e. rugged terrain, potential for avalanches, landslides, flash flooding, etc.)
Working/traveling in politically unstable countries or war zones
Travel to countries where epidemic disease requires additional immunizations and specific mitigation strategies, including vaccines
Any activity that involves travel through or to a country or region for which a travel or health advisory is in effect

In some circumstances, the risk may be evaluated as unmanageable (see the definition of Unmanageable Risk in this Procedure).

Risk: The likelihood of encountering an identified hazard and the gravity of the consequences of such an encounter.

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 are outlined in the Risk Assessment Procedure.

Related Policies, Procedures, Guidelines:

Accommodation of Disabilities in the Workplace Policy

Academic Accommodations for Students with Disabilities Policy

Health and Safety Management System Policy

Policy Statement on Health and Safety

Procedures Superseded by this Procedure: N/A

Responsible Officer: VP, Finance and Administration

Contact: Director, Environmental Health and Safety

Date for Next Review: January, 2028