NJSS

There is no state-mandated minimum or maximum number of students who are permitted to participate in the SLE or co-operative education program. That is a district decision.
All students who are placed into SLEs and co-operative education programs must be supervised by an authorized teacher or coordinator.
For SLEs, SLE teachers and co-operative education coordinators may supervise the students.
For co-operative non-hazardous education experiences, co-operative education coordinators may supervise co-operative education experiences. CTE teachers may also supervise their own students in co-operative education experiences if they are appointed and complete the SLE courses.
For hazardous co-operative education experiences, co-operative education coordinators-hazardous occupations may supervise co-operative education experiences. CTE teachers in hazardous areas may also supervise their own students in co-operative education experiences if they are appointed and complete the SLE courses.
SLE teachers may not supervise co-operative education students under any circumstances.
Job coaches may not supervise SLE students under any circumstances; instead, they provide support services to the student during an SLE or co-operative education experience. The student must still be supervised by the SLE teacher or co-operative education coordinator while at the worksite.
All SLE (paid and unpaid) worksites must be visited by the supervising teacher or co-operative education coordinator once every tenth day that the student reports to that site. The same is true ofco-operative education (hazardous and non-hazardous): they must be supervised once every 10^th day by the co-operative education coordinator (or CTE teacher as described in #4 and #5, above). If the student is reporting every day, then the worksite must be visited every two weeks. If the student is reporting twice a week, then the worksite must be visited every five weeks. Note that the student must be present at the worksite during the mandatory visit.
Districts may decide to visit students more frequently, but they cannot visit less frequently. This is a child labor regulation.
If you cannot meet the site visit requirement, then the district must: (1) reduce your classroom load if you are teaching, or (2) reduce the number of students placed into SLEs in order to comply with the child labor regulations.

Is there an SLE curriculum? I am writing three different curriculums for a transitions program that our high school will use, and I was wondering if there was one for SLEs.

Sorry, not at this time. You may want to take a look at the 12th Grade Option Resource Packet found on the SLE homepage. It contains general information for designing unpaid SLEs (minus the requirement that the students have completed their graduation requirements). www.state.nj.us/education/cte/sle/

Are districts required to provide transportation for students participating in SLEs?

In most cases, no. Students are required to make arrangements for their own transportation when participating in SLEs or co-operative education experiences, unless a student has an IEP that requires the district to provide transportation.

One exception is job shadowing, which is typically handled like a field trip where a group of students and a teacher travel on a bus or other school vehicle to visit a job site or sites for a day or less. Districts may choose to provide SLEs in-district for those students who have no access to transportation.

The NJ Department of Education does not, in fact, approve SLE or co-operative education sites. Local districts are the approving agencies, which is why you are all sent to training, especially the OSHA General Industry training program, to help prepare you to make those site approvals.

A service provider that is not a NJ Department of Education-approved private school for the disabled is permitted to provide support services to a student on behalf of the school district. The service provider, however, cannot do any of the following:

Approve worksites or community sites where the SLE will take place;
Approve the individual student training plans for the SLE activity;
Sign the student training plan and SLE training agreement on behalf of the district; or,
Conduct the mandatory on-site supervision visits once every 10th day the student reports to the SLE site as required by NJ Child Labor regulations (NOTE: visit length/time is not specified).

Furthermore, a service provider does not have the authority to do any of the above activities because the service provider is not a receiving school district (district). Therefore, the district retains its legal authority and responsibility with regard to the SLE placements.

The contracted service provider may, however, conduct the following activities on behalf of the school district (district):

Identify and develop SLE sites (this includes community-based placements) for district approval;
Draft individual student training plans for consideration and approval by the district;
Conduct ongoing learning support for students placed at SLE sites (this includes community-based placements) such as job coaching;
Conduct formative assessments for review and approval by the district;
Serve as a conduit between the employer/SLE site, the student and the district; and,
Make recommendations for continuance, completion and/or removal of a student from an SLE site for approval by the district.

Can the school appoint more than one teacher to supervise the SLEs?

Yes. Any public school district, charter school or private school for the disabled may appoint more than one teacher to supervise SLEs, if needed, as long as the additional teachers have completed the SLE courses and the school appoints the teachers to function in that capacity. Note that districts and schools are not limited to appointing SLE teachers at the start of the school year.

How many students can participate in an SLE?

There are no regulations or statutes that directly limit the number of students that a district can place into an SLE or co-operative education experience. However, the New Jersey Department of Labor and Workforce Development’s regulations require that the teacher/coordinator visit the student at the worksite at least once every 10^th day the student reports to the worksite, regardless of whether the experience is paid or unpaid. Therefore, the district must be able to meet the following conditions when planning its SLE program:

The teacher/coordinator must be able to conduct the required site visits while the students are present at the worksite.
The site visit is designed to give the teacher/coordinator an opportunity to observe the student’s activities at the site, speak to the student’s mentor and/or the employer, and complete any necessary paperwork.
If the teacher/coordinator is using the NJ Department of Education model worksite checklist form found on the SLE homepage (www.state.nj.us/education/cte/sle/), which is strongly recommended, the teacher/coordinator should provide a completed and signed copy to the employer for their records prior to leaving the site.
The teacher/coordinator’s travel time to and from the worksite must be incorporated into the site visit plan. Therefore, distance traveled will impact the site visit schedule.

All of these elements will influence the maximum number of students that the district may place into SLEs and co-operative education experiences.

If the district cannot meet the site visit requirement, then the district’s options are to appoint/hire additional SLE teachers or co-operative education coordinators or reduce the number of students placed into SLEs and co-operative education experiences. If your district administrator has any questions about this requirement, print out this out for him/her.

My student is enrolled in a CTE program in carpentry. Is there any special training he should receive before placing him in a co-op?

Yes.

First, the student must be enrolled in a NJ Department of Education-approved career and technical education program for carpentry (or whatever content area supports the co-operative education experience).
It is up to the teacher to decide when a student is ready to participate in the co-operative education experience, but the student must be at least 16 years old. Typically, districts use co-operative education experiences as a capstone course for seniors.
The student must be proficient in using the equipment that they are expected to use at the worksite. Proficiency is determined by the teachers.
The student must pass a teacher-generated lab/shop safety test for the hazardous equipment that is used in the class lab/shop. The test is administered in the lab/shop and “pass” means they must achieve 100%. If there is an equipment safety test available from the equipment manufacturer, it is permissible to use, in lieu of the teacher-generated lab/shop safety test.
The student must pass a worksite safety test on the actual equipment that the student will use at the co-operative education experience worksite. The co-operative education coordinator and employer may work in tandem to decide what kind of safety test will be administered. Again, “pass” means 100%.

NOTE: If the student cannot receive training on a piece of hazardous equipment in the career and technical education program’s classroom, then the student is not permitted to use that equipment at the co-operative education worksite. The equipment brands do not have to be the same, but the equipment type must be. For example, a student must first be trained to use a gas range in the classroom prior to using a gas range at a worksite. The student’s first use of a piece of hazardous equipment must be in the classroom. First use cannot occur at a worksite because that is not a controlled learning environment.

Both parties will keep copies of the student’s safety test and results on file.

Without hands-on training and safety tests, the district cannot attest that the student is ready to participate in a hazardous co-operative education experience.

NOTE: Under no circumstances can students who are not enrolled in a NJ Department of Education-approved career and technical education program for that hazardous occupation be permitted to participate in a hazardous worksite experience.

Can I use a job my student obtained as an SLE placement?

In any SLE, including co-operative education experiences, productive work is incidental to the learning activities the student is engaged in at the worksite. SLEs are learning experiences (the LE in SLE).

When an employer hires a young person for a job, the employer has an expectation that the student will meet certain performance criteria in exchange for the wages paid, and rightfully so. When a coordinator places a student in an SLE, learning is the primary worksite expectation of the student, and those expectations should be established prior to the student’s placement.

How can we realistically expect an employer to reconcile these two fundamentally different objectives at one time? We can’t, and shouldn’t.

It is the coordinator’s responsibility to obtain SLE placements for participating students, and such placements are to be established with the student learning objectives in mind. SLEs are not about getting students jobs or students getting their own jobs. Remember, all SLEs must be graded activities because they are learning activities.

Can I place a student in a home as a babysitter for an SLE?

All students participating in SLEs, including co-operative education experiences must be supervised at all times by a worksite mentor in accordance with Child Labor and Wage and Hour Regulations. Babysitting, by its very nature, does not meet that requirement, so the answer is no, you cannot place a student in a babysitting SLE.

Is a job washing dishes allowed under the SLE paid job experience?

Yes, dishwashing is allowed as a paid SLE job experience because dishwashing in itself is not hazardous. However, caution is advised when inspecting the site where the student would work and to pay attention to where the dishwashing station is located. If there are hazards present, such as water on the floor, a lack of appropriate rubber mats to stand on to prevent slip hazards, or proximity to electrical outlets, for example, it would not be an appropriate placement. Also keep in mind the cognitive ability of the student. For instance, students who have attention deficits or other handicaps may not be able to safely navigate a busy, congested kitchen, especially if the dishwashing station is close to hot cooking surfaces, such as grills and stoves. In those cases, the worksite may not be an appropriate setting for an SLE.

Can a student participate in an SLE or unpaid internship over the summer? Is the school district responsible for insurance? Is there an insurance waiver between employer and family?

A student may participate in an SLE over the summer; however, all of the district’s responsibilities for offering an SLE during the school year apply to a summer SLE. That includes district insurance coverage for the student and supervision of the student once every 10^th day the student reports to the SLE site by the district’s SLE teacher or co-operative education coordinator. If the district is unwilling or unable to provide these services during the summer, then the SLE ends at the end of the school year. The employer host has the option of hiring the student for the summer as a paid employee.

If students are volunteering their services in our school for maybe 10 hours per week, do they need an unpaid SLE, a volunteer SLE, nothing or what? Help?

There are several conditions that you have not indicated. (1) Will the student receive a grade or graduation credit for the experience? (2) Is the volunteer experience part of a school program or graduation requirement? (3) Or, is the student simply volunteering on their own time?

If the answer is (3), then the district does not have to do anything. If the answer is (1) or (2), then the district would prepare a student training plan and supervise and assess the student’s experience, just like any other SLE. However, the district does not have to prepare and sign the training agreement with itself.

It is important to understand that regardless of what a district does or does not name its work-based learning program, the activities are all structured learning experiences under regulation and hence fall under the requirements for SLEs. That means the district must comply with all SLE rules and regulations pertaining to staff, site inspections, student supervision, documentation, etc.The individual supervising the SLEs must hold a standard teaching certificate with at least one year of successful teaching under that certificate, and must have completed the required SLE courses prior to appointment.

Is there a maximum number of SLE hours a student may accumulate at one given placement?

The answer is that it depends upon the Student Training Plan.Child Labor Regulations limit the number of hours a student may work, paid or unpaid, in an SLE or co-operative education experience per school day to eight (8) hours of combined school and work.

But the total number of hours a student can work as part of a particular SLE or co-operative education experience is dependent upon the learning objectives developed for the student’s training plan. Once the student has accomplished those learning objectives, the student should be removed from the SLE site. This is because once the learning objectives have been accomplished, the student’s hands-on activities would no longer be considered “learning activities” and the student would no longer be considered a “student,” but rather an employee under State and Federal Wage and Hour Regulations.

Remember, the student training plan determines the amount of time the student should spend at an SLE site. Use your formative assessments to keep track of the student’s progress towards accomplishing the learning objectives in the training plan to determine if any adjustments must be made to the end date of an SLE. If you change an end date, particularly if it is an unpaid SLE, be sure that the district and SLE host are in agreement and document that agreement to a changed end date.

Is there a requirement that a senior cannot participate in an SLE ifhe/she has not passed the High School Proficiency Assessment?

No. There is no administrative code that makes having achieved a certain grade or passing the HSPA exam a requirement for student participation in structured learning experiences.

You may be thinking of the Senior Year Option initiative that the NJ Department of Education launched during the McGreevy administration. The Senior Year Option initiative offered senior students who had completed their graduation requirements the option of participating in internships or enrolling in college courses during their senior year. The goal of the initiative was to enrich students’ senior year.

Student eligibility requirements for participating in structured learning experiences are a district-level decision, unless a student’s IEP requires an SLE.

A student who is 18 has a job which is during the 11 pm – 7 am shift. The parents want the district to offer a co-operative education experience for this student’s job. Can the district do this?

First, in order for a job to be considered for a co-operative education experience, the job must be related to the occupation for which the student is studying in his or her career and technical education program. Co-operative education experiences are not work/study. They are a course that is part of a career and technical education program, and it must be related to that career and technical education program.

Second, the 11 pm-7 am shift would not be an appropriate co-operative education experience for several reasons:

The impact that this work schedule would have on the student’s learning and education, in general, is not appropriate for school-sponsored experiences.
Importantly, there would be no district supervision. It is neither likely that a co-operative education coordinator would be authorized by his or her school contract to work during the hours of this shift, nor is it likely that the coordinator would want to conduct worksite visits during the midnight shift. Therefore, the district cannot provide supervision of the worksite, so the work experience does not qualify to be part of a school-sponsored co-operative education experience.
Finally, districts are not obligated to turn jobs obtained by students on their own into co-operative education experiences simply because students or their parents want them to be co-operative education experiences. Districts are responsible for designing and executing their co-operative education programs in a manner that fosters the educational experience of students, protects student health and safety, and are in compliance with state and federal regulations and laws.

If the employer requires everyone to be fingerprinted, is that permitted if the student is a minor and the placement is an SLE or co-op?

Both Federal (U.S. Department of Labor) and New Jersey (Labor and Workforce Development) Wage and Hour Division experts have indicated there are no prohibitions in either Federal or State child labor statutes, regulations or hazardous orders that would prevent a minor from being fingerprinted as part of a job/SLE placement. However, the district is advised to notify a student’s parent or guardian of the fingerprinting requirement, and receive written permission permitting the fingerprinting prior to making such a placement.

The Juvenile Justice Commission (JJC) responded that if you read the job application carefully, it says “convicted of a Felony.” All juveniles have never been “convicted;”they have been “adjudicated.” It is considered a technical difference, but according to numerous sources of the JJC, juveniles who have been adjudicated can answer “No” on this question.

There are several issues to take into consideration here, the first being that there are no exemptions or exceptions for family-owned businesses regarding New Jersey Child Labor Laws and Regulations or NJ Department of Education Administrative Code pertaining to structured learning experiences (SLES) and co-operative education experiences. This scenario also creates the following problems:

The student must be supervised by an adult worksite mentor at all times. In this case, the student would not be supervised by anyone from the company;

The SLE teacher would have to inspect and approve the home as an SLE site, which is not an appropriate situation in which the SLE teacher should be placed; and
The SLE teacher would have to conduct the worksite visits in the student’s home; again, not an appropriate situation for the SLE teacher.

For all of these reasons, this scenario should not be approved by the district for a school-sponsored SLE.

There are currently no regulations prohibiting an SLE placement in a family-owned business. There are also currently no regulations prohibiting a parent from being the student’s worksite mentor. Although this type of worksite placement might not be an ideal situation for students, it is not prohibited. When drawing up the student training plan, the SLE teacher must give careful consideration when considering how to document the student’s accomplishment of the SLE goal/objectives. The SLE teacher should ensure there is an opportunity for him or her to confirm the student’s achievement of the goal/objectives, which would also be the case in any other SLE placement.

If a student is placed in an SLE at a family-owned business at the family’s home, do I have to conduct the site visits?

YES. There are no exemptions for family-owned businesses regarding compliance with Wage and Hour and Child Labor laws and regulations and NJ Department of Education administrative code, so all SLE or co-operative education requirements must be put into place, including the required paperwork. All required site visits must also be conducted, regardless of where the family-owned business is located. That means the teacher coordinator must conduct a site visit at the student’s home if that is where the work activities will take place. If the parent objects to the site visits, then the district cannot place the student at that worksite as part of a school-sponsored SLE.

I have a family-owned business situation where the father does notpreferto put the son "on the books." Would this be acceptable for an approved site? The student is getting paid.

No, this situation may not be used for a paid, school-sponsored SLE. The student must “be on the books,” i.e., receive at least minimum wage, have all relevant taxes paid. If the father is not willing to do this, then do not accept this site as a school-sponsored SLE.