Petition Number: P-05-931

Petition title: Sun cream in schools

Text of petition: All children are at risk when in school or on school trips of sun burn. This not only has short term health issues but also long term such as skin cancer. This could easily be avoidable by allowing schools to apply sun cream with parents' consent. There are many options for this that do not involve the teachers having to touch the children if this is an issue.



The issue of sun protection in schools, in particular for young children, is one that frequently arises during the hottest months of the year. It can sometimes attracts media coverage, including coverage of this specific petition from the BBC, Mirror and the Metro.

There are several aspects to the issue being raised including public health, health and safety, education and child protection. Of relevance in an education setting is that the Foundation Phase curriculum for all three to seven-year olds in Wales encourages learning through play and a greater emphasis on using the outdoor environment as a resource for children’s learning.

Suggested guidelines

Deciding on the policy for an individual schools is currently the responsibility of School Governors. However there are a number of options for suggested guidelines including these from Caerphilly Local Public Health Team and this Cancer Research UK website and its SunSmart guidance for primary schools.

Public Health Wales run the Welsh Network of Healthy School Schemes. The Indicators for its National Quality Awardmake a number of references to sun safety. It says that a Safe School Policy should include sun safety and points to the Cancer UK SunSmart guidance.

There is also information on this Sun Safe Schools website and a suggested approach in its accreditation scheme.

Section 25 of the school governors guide to the law explains health and safety responsibilities in schools, and matters which are relevant to pupil health but it does not mention sun safety specifically.


Assembly Inquiry in the Fourth Assembly

Terms of reference

In 2011 the Assembly’s Petitions Committee received a petition from the cancer charity Tenovus calling on the Welsh Government to provide free sunscreen for all children under the age of 11 in Wales. This petition was referred to the Children and Young People Committee for consideration, who held a short inquiry looking at

§  whether current sun protection policies and guidelines for schools are effective in providing sufficient sun protection for children, and if not, where improvements are required;

§  whether there is sufficient awareness of the current sun protection policies and guidelines, and, if not, how best to raise awareness;

§  whether there are any barriers to the use of sun protection in schools, including sunscreen, suitable clothing, hats or shade, by children and young people, for example in terms of cost or the application of sunscreen by teachers or childminders, and if so, how these could be addressed.

Points raised in evidence

In written evidence to the inquiry in 2012 the Welsh Local Government Association said:

In terms of the application of sunscreen for younger children who were unable to apply their own, there could be child protection implications. However, schools and childminders are subject to strict checks and safeguards can be put in place to ensure that the risks are minimised. This should be seen in the context of the overall child protection procedures within schools.


Public Health Wales said in 2012:

National guidelines recommend that schools should have a sun policy but they are not prescriptive or mandatory. Currently, the decision whether or not to deliver sun safety advice is left largely to the discretion of the individual teacher.


It also said:


There are sensitivities around whether it is appropriate for school staff to apply sun screen to children and young people and it is vital that primary schools place particular emphasis on encouraging changes in the habits of parents/carers as well as children and young people. Local authorities and school governing bodies should formulate their own policies on this.


Commenting on the position of school staff applying  sun cream the National Association of Headteachers and the Association of School and College Leaders said in 2012 refer to children too young to apply the cream themselves, and the issue of who will do it for them.


Many schools demonstrate to children how to apply sun screen. This is reasonable and sensible. Schools often help the very youngest children to apply sun screen. While this might seem entirely sensible in individual cases we, as professional associations advise against doing so, for the equally sensible reason that physical contact can be misinterpreted with catastrophic consequences for members of staff.


Similar concerns apply in relation to particularly vulnerable pupils where significant child protection issues are involved. Introducing a duty on schools in this regard would encounter strong resistance from members of staff who might be instructed to apply it.


In its written response to the Committee in 2012 Undeb Cenedlaethol Athrawon Cymru (UCAC)referred to a number of considerations. Specific to the application of sun cream it said that increasingly teachers are increasingly advised to touch children as little as possible to avoid any allegations of abuse or inappropriate touching. It also referred to potential hygiene issues if teachers applied cream to multiple children.

What the Committee said

The Committee’s report, published in 2012, said that ‘some concern was expressed about the application of sunscreen to children by school staff’. Relevant to the issue of school staff applying sun cream, the report also refers to concerns raised in the written and oral evidence about any proposal to make the provision of sunscreen in schools compulsory, including hygiene, potential allergies, time and resource implications, and potential child protection issues. The report says:

The Committee took the view that if sunscreen were to be provided in school settings, regardless of whether it was provided by parents or schools, greater clarity would be needed on existing guidance in respect of teachers, childminders or nursery school staff having physical contact with children in order to apply sunscreen.


The Committee made six recommendations including one that:


As part of schools’ broader health and safety policy, they should be required to have a document which sets out the school’s approach to a range of environmental factors which might affect children during the school day, including sun protection and shade requirements, and wet or cold weather.

The Welsh Government's response detailed its views in 2012 on all the recommendations.

Welsh Government’s response

In response to this Petition, on 27 November the Minister for Education made several points including:


§  Health and safety is not devolved to the Welsh Government and the responsibilities in schools are derived from the Health and Safety at Work Act 1974 and the associated Management of Health and Safety at Work Regulations 1999.

§  Statutory responsibility for the health and safety of pupils lies with the governing body of the school, either as the employer of school staff or because it controls school premises, in many cases both.

§  Under the general law of negligence, school teachers are required to take care of children under the age of 18 as if they were the parent. They are under an obligation to treat and take care of a pupil as a careful parent would.

The response also refers to guidance from the Welsh Network of Healthy School Schemes, which suggests that schools should:

§  Actively consider sun exposure risk when planning outdoor activities during the summer.

§  Engage with parents to agree a local approach to the provision and application of sunscreen of at least Sun Protection Factor (SPF) 15.

§  Actively encourage parents to provide hats, sunglasses and appropriate clothing during the summer and particularly when outdoor activities are planned.

§  Ensure that the school grounds have access to shade for very hot days.

§  Avoid prolonged outdoor activities during the hottest part of the day i.e. 11am – 3 pm between March and October.

Every effort is made to ensure that the information contained in this briefing is correct at the time of publication. Readers should be aware that these briefings are not necessarily updated or otherwise amended to reflect subsequent changes.