Standards of Best Practice

Duke University has developed the following Standards that all Programs, where applicable, must follow. Any deviations, once approved by HR, must be clearly discussed in Program materials, including in the Program Description of the relevant Participation Agreement.

• Supervision Policies
  • Ratios
  • Appropriate Supervision
  • Prohibition of One-on-One Interaction
• Behavioral Requirements for Program Staff
• Identification of Program Staff
• Health and Medication Policies
  • Review Health Forms
  • Medication Management
  • Nurses
• Incident Reporting Criteria
• Emergency Preparedness Plan
• Transportation
• Visitors
• Drop-off and Pick-Up Procedures
• Use of Photographs in Online Postings and Program Materials
• Program Fee, Refund, and Withdrawal Costs Information
• Written Handbook for Overnight Programs

Supervision Policies

A. Ratios

The following supervision ratios recommended by the American Camp Association are to be maintained at all times. If the Program has Minor participants from different age ranges, the lowest age range should be used to determine the appropriate supervision ratio.

Age of Minor	Ratio for Day Programs	Ratio for Overnight Programs
5 years and younger	1:6	1:5
6-8 years	1:8	1:6
9-14 years	1:10	1:8
15-17 years	1:12	1:10

B. Appropriate Supervision

Minors should be supervised with line-of-sight supervision at all times, including when travelling to different locations or off-campus. If the Program desires to have some flexibility in supervision, please consult with the HR Youth Protection Coordinator to determine if it would be appropriate to allow such flexibility and, if so, to develop check-in procedures and clear boundaries for the areas Minors will be allowed to explore. Any such flexibility in supervision shall be granted only in express written authorization from the HR Youth Protection Coordinator.

C. Prohibition of One-on-One Interaction

Program staff should not be permitted to be one-on-one with a Minors, and Programs should employ at minimum the principle of "two deep leadership" which includes the presence of a second adult at all times.

If one-on-one interaction is essential to the Program, assure the meeting or activity is in public space, in a place containing windows with clear visibility into the room, or in a space where the door can be left open. In these situations, Program communication with the parents should be clear on the abuse prevention methods the Program is implementing to mitigate risk. In the cases of a private lesson or instruction where the only option is one-on-one, the parent should sign a specific waiver to the situation, acknowledging that there will be unsupervised contact and giving consent for the one-on-one lesson or session; in the case of a private lesson or activity, the parent will be offered the option to sit/drop in on the lesson at any time.

Behavioral Requirements for Program Staff

Adults working in Minors Programs must follow these expectations to avoid behaviors that could cause harm or be misinterpreted. Programs must educate their program staff on these requirements.

• Do not engage in any sexual activity, make sexual comments, tell sexual jokes, or share sexually explicit material (or assist in any way to provide access to such material) with Minors.
• Do not be alone with a single Minor. If one-on-one interaction is required, meet in public space, in a place containing windows with clear visibility into the room, or in a space where the door can be left open.
• Do not meet with Minors outside of established times for Program activities. Any exceptions require written authorization by a parent/legal guardian and must include more than one adult from the Program.
• Do not invite individual Minors to your home. Any exceptions require authorization by the Program Director and written authorization by a parent/legal guardian.
• Do not engage or allow Minors to engage you in romantic or sexual conversations, or related matters, unless required in the role of resident advisors, counselors, or health care providers.
• Do not engage or communicate with Minors through email, text messages, social networking websites, internet chat rooms, or other forms of social media at any time except and unless there is an educational or programmatic purpose and the content of the communication is consistent with the mission of the Program and the university.
• Do not touch Minors in a manner that a reasonable person could interpret as inappropriate. Touching should generally only be in the open and in response to the Minor's needs, for a purpose that is consistent with the Program's mission and culture, and/or for a clear educational, developmental, or health related (i.e., treatment of an injury) purpose. Ask for permission before initiating any touching, and any resistance from the Minor should be respected.
• Do not engage in any abusive conduct of any kind toward, or in the presence of, a Minor, including but not limited to verbal abuse, striking, hitting, punching, poking, spanking, or restraining. If restraint is necessary to protect a Minor or other Minors from harm, all incidents must be documented and disclosed to the Program Director and the Minor's parent/legal guardian.
• Do not use, possess or be under the influence of alcohol or illegal drugs while on duty or when responsible for a Minor's welfare.
• When transporting Minors in a Program, more than one adult from the Program must be present in the vehicle. (Please review the Transportation Guidelines for additional information.)
• Possession of or use of any type of weapon or explosive device is prohibited.

Identification of Program Staff

Program staff and participants must distinguish themselves at all times for easy identification. For residential camps, Program Staff should wear shirts identifying the Program they are working with at all times while they are with working with Minors. Participants may wear lanyards, badges, t-shirts, name tags, etc. Whichever identification method is chosen for participants, it must be clearly displayed at all times throughout the Program.

Health and Medication Policies

A. Review Health Forms

Where applicable, Program staff must review submitted Health Forms before the Program begins to ensure that Minors have completed all requirements, that a licensed health care provider has signed off on any medications a Minor will bring to the Program, and that the parent/legal guardian and a licensed health care provider have verified the Minor's ability to participate in the Program.

B. Medication Management

Minors are not allowed to hold any medications. (The only exceptions will be for acne creams and urgent-need medication such as insulin, rescue asthma inhalers, epinephrine and glucagon devices, which Participant may keep with them if approved by a physician in the signed Health Forms.) Medications includes any substance a Participant takes to maintain and/or improve their health, including vitamins and natural remedies.

Program staff must develop a procedure for securely housing medications and accurately tracking which medications have been distributed to Minors, using the parameters below. For overnight camps, medications should be checked-in as part of the arrival day check-in procedure. Day camps should also be prepared to handle medications as needed.

1. A prescription or nonprescription medication may be accepted only in an original container. The medication must remain in the container in which it was received. The label must identify the names of the medication and the child for whom the medication is intended.
2. Medication shall be stored in a locked area of the facility or in an area that is out of the reach of children. Further, medication shall be stored in accordance with the manufacturer's or health professional's instructions on the original label.
3. Program staff shall provide medication to a Participant only if written instructions are provided from a licensed health care provider. Instructions provided in the Participant's completed Health Forms are sufficient.
4. Program staff should establish and maintain a medication log if prescription or nonprescription medication is distributed. Medications should not be distributed in advance of need. A log must include the following minimum information:
   1. The name of the medication.
   2. The name of the child receiving the medication.
   3. The amount of medication administered.
   4. The date of administration.
   5. The time of administration.
   6. The initials of the staff person who administered the medication.
   7. Special notes related to problems of administration.

Programs may request epi-pens from Duke Student Health to have on hand in case of emergencies. Duke Student Health will also be able to facilitate training on use of epi-pens.

C. Nurses

Each Program is recommended to have a nurse on-site.

Incident Reporting Criteria

Please report all Program incidents to HR. For purposes of reporting, an incident is any event involving:

• Instances covered in the Minors Policy Reporting Requirements (for any such instances, additional reporting requirements may apply, as set forth in the Policy)
• Other serious harm or risk of serious harm to a Minor
• Possibility for Minor to be sent home from the Program
• Inappropriate behavior by a staff member towards a Minor
• Possibility for terminating employment of a staff member
• Involvement of police or law enforcement
• Complaint from parents as it relates to the safety of a Minor
• Reported occurrence of sexual behavior by Minor participant or staff member

If you are unsure whether an incident needs to be reported, please contact the HR Youth Protection Coordinator.

Emergency Preparedness Plan

Each Program should develop site-specific emergency procedures to respond to natural disasters typical of the area and other reasonably foreseeable emergencies. These procedures should include guidelines on immediate actions to take to safeguard participants and staff, and a communications plan. Please consult the Duke University Emergency Management Plan for further information.

Transportation

Program staff who perform transportation activities must complete an approved motor vehicle background check prior to operating a Duke vehicle. Program staff are not allowed to transport Minors in their own personal vehicles or any non-Duke vehicle.

Large passenger vans (such as 12 or 15 passenger vans) should not be used to transport Minors.

Minors are not allowed to arrange their own transportation to and from Program sites. If the Program desires to allow older participants to drive themselves to and from Program sites, please consult with the HR Youth Protection Coordinator to develop clear check-in and check-out procedures.

Minors are not allowed to use rides arranged via transportation network companies (e.g., Uber or Lyft) or similar ride-share arrangements, even if requested by the parent/legal guardian.

Visitors

Visitors are typically not allowed except in extreme circumstances. Any allowed visitors must be over 21 years old and approved in advance in writing by the parent/legal guardian. Visitors must check in and check out with Program staff when they arrive and depart and must verify their identity with Program staff by showing a driver's license or other official identification.

Drop-off and Pick-Up Procedures

Where applicable, Programs should develop a procedure for drop-off and pick-up from their Programs, including policies for where cars can drive/park, who is authorized to collect a Minor, and what to do in the event a parent/legal guardian is late to collect a Minor.

Use of Photographs in Online Postings and Program Materials

Per the Participation Agreement, Program may make use of photos, videos, or student work in Program materials in print and online. However, Programs should not post identifying information about any Minor, such as first and last name, when making use of photos or videos including Minors or work created by a Minor.

Program Fee, Refund, and Withdrawal Costs Information

Programs should develop written policies for how to handle requested refunds of program fees and make this information available to parents/legal guardians, e.g. by posting it on the Program website or including in Program materials.

Written Handbook for Overnight Programs

Overnight Programs are required to include these standards and all other relevant information in a written handbook. Such Programs must also develop staff training covering important information and, where appropriate, address this information during orientation for Program participants as well.