Our response to this DfE consultation on HASLOC suggests clarifications and changes, and notes the Society's relevant experiences with BS 8848.
Response submitted 2010
1. Make explicit reference to the statutory requirements in the National Curriculum that require pupils to undertake their learning outside the classroom, such as fieldwork in geography and similar activities in other subject areas.
2. Provide greater clarity in relation to the materials audience/s. It currently aims to be both a ‘higher level’ document and a guide for ‘front line’ professionals. Key sections of the draft document could be usefully separated, and ‘tagged’, along these lines. In addition, the tone of the document whilst being encouraging does not sufficiently highlight those things teachers must do, alongside the activities that they might undertake.
3. An exercise must be undertaken to ensure that the HASLOC guidance is consistent with the materials on the LOTC website in relation to language, terminology and structure. It is currently difficult to cross reference the HASLOC guidance to the respective areas of the LOTC that provides guidance for teachers in how to undertake safely planned LOTC activities.
4. The section “where does learning outside the classroom take place?” (pg7) needs to include as additional bullet point highlighting that such work can take place in the UK or overseas.
5. The continuing importance and relevance of “teacher led” LOTC activities, such as geographical fieldwork, need’s further exemplification. For most schools teacher led activities will continue to be the predominant type of LOTC activities. This could be usefully done after the section “Where does learning outside the classroom take place? Pg 7” with a new section titled as follows:
In the main it will be teachers who organise LOTC activities supported by other colleagues in their schools.
In addition, schools also use third party providers which might cover all or part of the LOTC activities, which might include transport, the LOTC activity itself, accommodation and other services.
This section should include reference to the benefit schools can gain from the use of “British Standard BS 8848: the national standard for the safe management of overseas ventures. BS 8848 provides a specification for organizing and managing visits, fieldwork, expeditions, and adventurous activities, outside the United Kingdom.” This standard is relevant to “Organizers of overseas activities including: adventure holidays, local education departments or other school employers, university and academic fieldwork, research expeditions, GAP year activities, travel and tour operators and charity challenges.”
This needs to ask the questions: What are you planning to do? When and where are you going to do this? How are you going to achieve the educational outcomes for this activity in a safely planned way?
This should include the additional bullet point “and you should act in accordance with the measures identified.
In the introductory text there is the suggestion that activities with no signification risk will be in or near the school grounds. There is then the statement “for more complex activities you can reduce your risk assessment by using a badged provider. This misses out the wide range of activities that teachers lead, beyond the immediate locality of the school, which will require them to undertake risk assessments of their own. Some of these will be straight forwards some complex. However this section, at the moment, has the potential to imply that ‘complex’ activities should only be undertaken through a badged provider.
This chapter notes that “risk management should reflect good administration and should not be bureaucratic or paper-heavy”. However, as currently written there may be the potential for it to be misinterpreted along the lines of – “all you need to do is fill in a form”. The Society would be concerned if the need for (where appropriate) pre activity visits to the respective locations was overlooked. In addition, the need for a risk review to underpin the ongoing and proactive checks a teacher should undertake during the planning of an activity and during the visit and in relation to the specific needs of the group.
The Society questions whether there is the need for schools to have (as proposed) a Learning Outside the Classroom Coordinator. We believe that the responsibility for ensuring that an out of school activity fully achieves its learning potential should be held within the appropriate curriculum area, be it the class-teacher, subject coordinator or Head of Department/Faculty. We cannot see what benefit this additional layer of bureaucracy would add.
Further, it is proposed that this new role sits alongside the existing role of the Educational Visits Coordinator (who is responsible for safety). Experience strongly suggests against having two or more colleagues with ‘similar’ responsibilities as it presents a significant potential for confusion, duplication and/or key responsibilities to fall between different people’s actions. Our involvement with BS8848 highlighted the need for clarity and continuity in the allocation of responsibilities for safety. The comments in section 1.11 illustrate this confusion where the LOTCC is identified as one colleague who could (alongside senior manager/head teacher & EVC) have specific risk management duties.
It is the Society’s view that proposal for a LOCC is an unnecessary additional burden on schools.
This has an over emphasis on ‘adventure’ rather than the full range of activities that might take place offsite. Further within this section it should be made clear that teachers themselves might hold the relevant skills and competencies to undertake adventurous activities e.g. a teacher might be about to demonstrate their suitability for leading a group through their holding of a Mountain Leadership qualification.
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