Risk assessing physical intervention for pupils with SEND: a guide for schools

When a school identifies that a pupil with SEND may need physical intervention to keep them or others safe, the risk assessment is usually written straight away. Too often it becomes a record of the risk the pupil poses to others, rather than an assessment of the risks to the pupil, the staff and everyone around them, including the risk created by the intervention itself.

At ProActive Approaches we approach risk assessment through #AimingForZero, the position our founder Simon Gower has held since 2016. A reduction target implies there is an acceptable number of restraints, and zero removes that permission. A risk assessment written from that position does not ask "how will we restrain safely?" It asks "what are we going to change so that restraint is not needed?" The legal duty to assess risk is the starting point. The purpose is to remove the risk.

What the guidance requires

The DfE guidance Restrictive interventions, including use of reasonable force, in schools says that where there is an identified risk, such as an increased likelihood that force or other restrictive interventions will be needed, schools must have risk assessments in place and, where possible, reduce the risk through measures such as training and prevention strategies.

The guidance also links risk assessment to the employer's duty under the Health and Safety at Work etc. Act 1974 to protect staff, so that staff who regularly work alongside pupils where interventions may be needed can do so as safely as possible. And it asks staff to take account of a pupil's medical conditions, SEND, age, size and other vulnerabilities in every decision about intervening.

The five steps, adapted for physical intervention

The Health and Safety Executive's guidance on managing risk sets out a familiar process: identify hazards, decide who might be harmed and how, evaluate the risks and decide on controls, record your findings, and review. Each step needs adapting when the subject is a child with SEND.

Step 1: identify the hazards

Start with the situations, not the child. Use incident records, the pupil's support plan and conversations with parents and staff to answer:

• Where and when does distress usually happen? Transitions, lunchtimes, specific lessons, transport?
• What tends to come before it? Noise, change, demands, pain, hunger, tiredness?
• What does the pupil do when distressed? Leave the room, run towards a road, hit out, self-injure, throw objects?
• What in the environment adds to the danger? Stairs, glass, heavy furniture, unlocked gates?

Step 2: decide who might be harmed and how

List everyone, and be honest about the pupil's own risk:

• The pupil: injury from their own actions, injury during an intervention, and psychological harm from being held, especially where there is past trauma or sensory sensitivity.
• Other pupils: physical injury, and distress from witnessing an incident.
• Staff: physical injury, and the emotional impact of repeated incidents.

Step 3: evaluate the risks and decide on controls

This is where most of the work should go. Order control measures from least to most restrictive:

1. Remove the trigger: change the timetable, the route, the seat, the lighting, the transition time.
2. Change the environment: a calm space the pupil can choose to use, secure gates, safer furniture layout.
3. Change how adults respond: agreed early warning signs, de-escalation steps, one lead adult, scripts in the pupil's language.
4. Staffing and training: named staff who know the pupil, trained to the level the assessment shows is needed.
5. Planned physical responses: only if the assessment shows they are still needed after everything above, limited to specific trained techniques, never on the ground and never affecting breathing or circulation.

For each risk, rate the likelihood and severity before and after controls. If a planned physical response is the main control for a risk, ask what else could be done first.

Step 4: record and share

The assessment should be short enough for the adults working with the pupil to read and remember. Link it to the pupil's behaviour support plan, so that each control in the assessment corresponds to an action in the plan. Our worked example of a positive handling plan for a pupil with SEND shows how the two fit together.

Step 5: review

Review the assessment after every significant incident, when the pupil's needs or medication change, when key staff change, and at least termly. The DfE expects behaviour support plans to be reviewed after every significant incident, and the risk assessment should follow the same rhythm.

Risks of the intervention itself

Every assessment that includes a physical response must assess that response. The DfE guidance is clear that any form of restraint, including seated and standing, carries a risk of physical and psychological harm and should be avoided where possible. Consider:

• Medical conditions: asthma, heart conditions, epilepsy, hypermobility, brittle bones, recent surgery, medication side effects.
• Physical factors: the pupil's size and weight relative to staff, any physical disability, and how they move when distressed.
• Sensory and communication needs: how the pupil experiences touch, whether they can understand what is happening, how they show pain.
• Trauma history: where known, whether being held may re-traumatise the pupil.
• Positional risks: the risk of going to the ground, and what staff will do if it happens.

Where medical factors are present, seek advice from the school nurse, the pupil's GP or paediatrician, or an occupational therapist, and record it.

A worked example: one risk, assessed properly

Leo is in Year 6 and has a diagnosis of ADHD and a learning disability. Incident records show he has left the classroom and run towards the school's front gate four times this term, each time during the transition from lunch to afternoon lessons.

• Hazard: Leo leaving the building and reaching the road outside the front gate.
• Who might be harmed: Leo, through a road traffic injury. Staff, through injury while following him. Leo again, through injury or distress if he is physically stopped.
• Risk before controls: likelihood high, severity very high.
• Controls, in order:
  • Leo returns from lunch five minutes before the main group, through the side door, with his key adult.
  • The front gate is kept closed and latched during transitions.
  • A movement break and a drink are built in straight after lunch.
  • Staff use the agreed early warning signs and offer the route to the sports field, which is enclosed.
  • If Leo still runs, staff follow at a distance and use their voice and positioning to guide him towards the enclosed field.
  • Physical contact only if Leo is at the gate and about to reach the road, limited to guiding him back, never on the ground.
• Risk after controls: likelihood low, severity very high.
• Review: after any incident, at the end of term, and when Leo moves to secondary school.

Notice that the first four controls have nothing to do with physical intervention, and that they target the time and place where incidents actually happen. That is what the guidance means by reducing risk through prevention strategies.

Sharing the assessment with every adult

A risk assessment only works if the adults who need it know what it says. In many schools, the staff most likely to be present when a pupil becomes distressed are lunchtime supervisors, supply staff and transport escorts, and they are also the least likely to have read the assessment.

• Produce a one-page summary with the early signs, the first three things to do and who to call.
• Include the summary in supply staff briefings and lunchtime team meetings.
• Keep it somewhere accessible but confidential, in line with your data protection policy.
• Check understanding, not just receipt. A two-minute conversation is worth more than a signature.

Reasonable adjustments and the Equality Act

For a disabled pupil, the school must take reasonable steps to avoid disadvantage under the Equality Act 2010. A risk assessment that lists only physical responses, without adjustments to the environment, timetable and communication, is unlikely to meet that duty. The DfE's Equality Act advice for schools explains the reasonable adjustments duty in more detail.

Common weaknesses we see

• Written about the pupil, not with the pupil and their parents.
• Risks to the pupil from intervention left out entirely.
• Generic controls such as "staff to use de-escalation", with no detail of what that means for this pupil.
• Named holds listed as the first control, rather than the last.
• Not reviewed after incidents, so the assessment no longer reflects reality.
• Staff wellbeing left out, even though repeated incidents affect the adults involved as well as the pupil.

Each of these can be fixed at the next review. The simplest test is to read the assessment and ask whether a new member of staff would know, from it alone, what to do differently tomorrow.

Training that matches the assessment

The guidance says staff likely to need restrictive interventions should be adequately trained in safe and lawful use and in preventative strategies. The risk assessment should drive the training, not the other way round. If the assessment shows that the main risk is a pupil running from the site, staff need skills in positioning, route planning and calm guiding, not a full syllabus of holds.

Our physical intervention training is built around a training needs analysis for exactly this reason, and our ProActive Schools programme puts prevention at the centre of every course.

FAQ

Is a risk assessment the same as a behaviour support plan?

No, but they should match. The risk assessment identifies risks and controls. The behaviour support plan describes, in practical terms, what adults will do. Each control in the assessment should appear as an action in the plan.

Who should complete the risk assessment?

Usually the SENCo or a senior leader, with the staff who know the pupil best, the pupil's parents and, where possible, the pupil. Health professionals should contribute where medical or physical factors are present.

Do we need a risk assessment for every pupil with SEND?

No. The duty applies where there is an identified risk that force or other restrictive interventions may be needed. Most pupils with SEND will never need one.

Can a risk assessment authorise restraint?

No. It can identify that a planned response may be needed and set limits on it. Every decision to intervene still depends on necessity and proportionality at the time.

How should we record a risk that has been removed?

Keep it in the assessment with a note of the control that removed it and the date. That record is evidence of the school's work to reduce restrictive interventions.