Interns and Graduates: 6 Health and Safety Duties Firms Overlook
Every summer, professional firms take in a cohort of people who have never worked in an office before. Vacation schemes, summer analyst programmes, graduate intakes, placement students and internships. They arrive keen, they are told the culture values commitment, and they work out what is expected by watching people who have been doing it for a decade.
Firms invest heavily in the recruitment and the training. Very few treat the cohort as what it also is: a population with less experience, less confidence to raise a problem, and a strong incentive not to be the one who complains.
That combination is a recognised risk factor, and it carries specific duties. Six that firms overlook.
1. Being over eighteen changes less than firms assume
The misconception that drives most of the rest.
There is a distinct regime for young workers, meaning those under eighteen. Regulation 19 of the Management of Health and Safety at Work Regulations 1999 imposes specific protections, and there are separate provisions on working time and rest. HSE publishes guidance on young workers. In most City firms this rarely applies, because interns are usually in their twenties, and firms therefore conclude that no special consideration arises.
That conclusion is wrong for a different reason. Regulation 13 of the same Regulations requires an employer, when entrusting tasks to employees, to take into account their capabilities as regards health and safety, and to ensure they receive adequate training on recruitment. Inexperience is a capability question at any age. HSE addresses the broader category in its material on vulnerable workers.
So the young worker regime usually does not apply, and the duty to account for inexperience always does.
2. Whether they are employees is not the question you think it is
Interns and placement students sit in varied legal positions: some employees, some workers, some on unpaid arrangements, some placed through a university.
Whichever applies, the health and safety position is broadly the same. The duty under section 2 of the Health and Safety at Work etc. Act 1974 covers employees, and section 3 covers persons not in your employment who may be affected by your undertaking. There is no arrangement under which a person working in your office falls outside both.
Firms occasionally treat unpaid or university-placed people as somebody else's responsibility. In practice the placing institution has its own interest and may ask you for your arrangements, which is easier to answer if they exist.
3. The induction that matters is not the one they get
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Induction for a summer cohort is typically substantial and almost entirely about the firm: systems, confidentiality, dress, expectations, who does what.
The health and safety content that actually matters is short and frequently absent. Where the fire exits are and what the procedure is, particularly for the floor they will actually sit on. Who the first aiders are and how to find one. How to report something that is wrong, including something about their own health. Whether anyone needs an evacuation plan, which is a question to ask everyone rather than wait for. And their workstation, because a cohort placed at hot desks for eight weeks is a DSE assessment population like any other.
Ten minutes, recorded. The record matters because it is what you would produce if asked.
4. Long hours are the actual risk, and they are foreseeable
The item that distinguishes professional services from most other sectors, and the one that deserves the most honesty.
Deal work, transaction closings, trial preparation and reporting cycles produce genuine peaks, and junior staff absorb them. A cohort that has never done this before will not calibrate well, will be reluctant to say they are struggling, and will take signals from the people around them about what is normal.
The Working Time Regulations 1998 provide entitlements including a rest break where daily working time exceeds six hours, and while opt-outs from the weekly average are common in these sectors, an opt-out does not dispose of everything else. There are also distinct provisions for young workers where anyone under eighteen is involved.
Beyond the entitlements, this is a stress assessment question. The HSE Management Standards identify demands, control, support, relationships, role and change, and a junior cohort in a peak period is at the sharp end of at least four of them. The peaks are in the calendar, so the exposure is foreseeable, which means it is assessable.
The practical controls are not complicated. Someone senior who is explicitly responsible for the cohort's wellbeing rather than their output. Permission to go home that is real rather than nominal. A route to raise a problem that does not run through the person setting the deadlines. And arrangements for getting home safely at night, which is a duty of care question that firms often handle well and rarely document.
5. They will not tell you when something is wrong
The behavioural reality that makes everything else harder.
A person on an eight-week assessed placement, hoping for an offer, will not volunteer that they have a health condition, that they are struggling with the hours, or that their workstation is hurting them. The absence of complaints from a summer cohort is not evidence that everything is fine.
The answer is to ask rather than wait. A brief structured check partway through, conducted by someone outside the assessment chain, surfaces more than any open-door policy. Make clear what will and will not be shared, because the fear of it affecting the offer is the reason people stay silent.
6. Your other offices take interns too
The complication for international firms running programmes in several countries.
Local requirements differ substantially and often bite harder on this population. Several European systems require training and medical arrangements before a person may begin work at all, rather than during onboarding. Poland requires a medical certificate and initial training before admission to work. Belgium requires prevention structures from the first employee. France requires psychosocial risk within the mandatory assessment document.
A group intern programme with a single onboarding pack will therefore be compliant in some offices and not in others, and the failure is at the start of the placement rather than at the end, which leaves no time to correct it.
The cohort checklist
| Item | Question | Usual answer | |---|---|---| | Capability | Has inexperience been factored into what they are asked to do? | Assumed away because they are adults | | Status | Is the arrangement covered whether or not they are employees? | Not considered | | Induction | Fire, first aid, reporting, evacuation needs, workstation, recorded? | Culture and systems only | | Hours | Are peak periods assessed, with real permission to stop? | Informally managed | | Voice | Is there a check-in outside the assessment chain? | Open-door policy only | | Other offices | Does each country's pre-start requirement get met? | One group pack |
The pattern is that the risks here are organisational rather than physical, which is why they survive assessments that look at premises and equipment. The office is safe. The arrangement around the cohort is what needs designing.
Where Arinite fits
Arinite works with firms that take in cohorts every year and want the arrangements to be proportionate rather than performative. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with legal, finance and banking and professional services organisations, where summer programmes and graduate intakes are a fixture of the calendar.
Where programmes run in several countries, our global health and safety consultants confirm what each jurisdiction requires before a placement starts, and our international health and safety consultants keep that current. Holding induction records, assessments and adjustments in one register across every office is where health and safety consultants and software are worth more together than either alone, and periodic health and safety audits confirm the arrangements operated rather than merely existed.
If your next cohort arrives in a few months and nobody owns this, a free gap analysis will identify what to put in place first.
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Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
