Minors in Research Laboratories

Subject: Minors in Research Laboratories

Date: September 2014

Revision: 1

Summary

This policy is issued by Environmental Health and Safety (EHS) in collaboration with Risk Management Services to provide guidance and consistency in the management of minors in research facilities.

Unsupervised volunteers and visitors, as well as children and pets, create a risk for injury and additional liability on the University. The Department of Environmental Health and Safety (EHS) recommends that a responsible person appointed by the Principal Investigator (PI), the Lab/Facility Manager, or the Department Head should supervise all visitors and volunteers when they enter a laboratory to work or visit. Departmental policy to this effect will reduce, or eliminate, the risk of personal injury to visitors in research laboratories and the risk of damage to projects and property. Additionally, there are other University policies and procedures that must be adhered to when minors are involved. This policy addresses those requirements for a comprehensive resource for University departments to reference.

Scope

This policy applies to all academic, clinical and service units involved in research operations involving minors. This does not apply to minors enrolled as UM-Dearborn students.

Definitions

Chemical Hygiene Plan – the UM-Dearborn Chemical Hygiene Plan is a written program that applies to all research, teaching, student and other laboratories at UM-Dearborn covered by the MIOSHA Hazardous Work in Laboratories Standard.

Department Head – This individual holds authority over a PI or other researcher and is in a position to review requests for visits. This raises the approval level beyond the individual lab or research facility.

Minor – A person under 18 years of age who is not enrolled in a degree program at UM-Dearborn. Policies apply whether the minor is employed or volunteering to work.

PI – Principal Investigator for a research activity

PPE – Personal Protective Equipment

Research Facility – includes any space

Responsible Person – any person approved by a Lab Director or Department Head to oversee and/or supervise the activities of a visitor/volunteer while in the research facility.

Responsibility

Deans, Directors and Department Heads

Actively support this Policy within individual units.
Review and approve requests for minors observing and working in UM Research Facilities.
Ensure individuals responsible for minors follow all requirements in SPG 601.34 Policy on Minors Involved in University-Sponsored Programs or Programs Held in University Facilities.

Supervisors/PI’s

Follow and implement procedures in accordance with this Policy to obtain approvals as required for minors and maintain documentation of approvals.
All responsible persons for minors must follow all requirements in SPG 601.34 Policy on Minors Involved in University-Sponsored Programs or Programs Held in University Facilities.
Provide ongoing supervision of all minors. Designate a qualified laboratory supervisor and an alternate supervisor, if necessary.
Never allow a minor to conduct research activities without direct supervision at all times.
Ensure minors are provided with PPE as required for their work.
Contact EHS to request training, technical assistance, and to evaluate health and safety concerns within their unit.

EHS

Review and approve minors working in research facilities.
Provide technical assistance to research operations regarding allowing minors into research areas.
Prepare and provide access to training tools for research operations.

Procedures

Observation-Only Visits – The minor is not conducting any research using hazardous materials or equipment.

Approval Process –
1. Anyone wishing to bring a minor into research facilities must first obtain the approval of their Chair/Department Head.
2. The request must include the purpose of the visit, duration and must identify a responsible person to oversee the visit. NOTE: Unless there is an approved purpose for the visit, children should not be permitted in research facilities.
PPE Requirements: Minors must be provided with appropriate PPE as needed based on work activity underway in the laboratory. At a minimum, safety glasses, long pants and closed-toe shoes must be worn.
Training: Observation only minors must receive a brief discussion of potential hazards that may be encountered in the laboratory during their visit and procedures to follow in the event of an emergency.

Minors Performing Research Activities (Volunteer or Employed)

General:

If a minor is to be employed refer to U-M SPG 201.20 Employment of Minors for a listing of jobs and titles that have State Department of Labor approval. Fourteen is the minimum age for legal employment.
The minimum age for volunteering is recommended to be sixteen.
Chemicals – minors are not allowed to work with any hazardous substance which means a contaminant, substance, mixture of substances which is toxic, corrosive, an irritant, a strong sensitizer, or flammable which generates pressure through decomposition, heat, or other means, if the substance or mixture of substances is capable of causing substantial personal injury, impairment, or illness through absorption, inhalation, or personal contact.
- Substances, as described above, would be designated with the signal word “DANGER”.
Biological Hazardous Substances – minors are not allowed to have potential exposure to any bloodborne pathogens.
Radioactive Materials – minors are not allowed to have any exposure to radioactive substances or ionizing radiation.
Animal Use – PI’s may apply for an exception to the ULAM Director to allow a minor to work with lab animals under the direct supervision of an Authorized User approved by the University Committee for the Use and Care of Animals (UCUCA).
Respirator Use – minors are not allowed to be assigned work tasks that require respirator protection including:

A self-contained breathing apparatus
A supplied-air respirator
An air-purifying respirator
A gas mask
A chemical cartridge respirator

8. Equipment Use – minors are not allowed to be assigned work tasks that involve the use of the following equipment:

Power-driven wood-working machinery
Power-driven metal-forming, metal-punching, and metal-shearing machines
Power-driven saws
Power-driven hoisting apparatus including a power industrial truck, crane, or hoist.

Approval Process:
1. Refer to SPG 601.34 Policy on Minors Involved in University-Sponsored Programs or Programs Held in University Facilities. Specific requirements regarding program registration, code of conduct, background screening, training and reporting requirements apply to minors working or volunteering in research facilities. Additional resources can be found on the U-M Children on Campus website.

All activities involving minors must be registered.
All individuals that will be supervising a minor must have training and background checks.

Complete the attached Project Checklist for Minors Performing Research in Laboratories form. Obtain approval from your Department Head or Chair.
Complete the attached U-M Informed Consent and Authorization Form. Obtain signatures of the minor and parent/guardian.
Once all signatures of are obtained as required, submit both forms for approval to EHS. Allow at least one week for Department Head or Chair approval and at least one week for EHS approval in advance of the planned visit. Additional time may be required if special approvals need to be obtained.
Approval of the work must be received prior to the visit and it must be available to produce upon request.
All minors who have not graduated from high school that are involved in paid employment must have a ‘work permit’ on or before the first day of work. Refer to SPG 201.20 Employment of Minors and consult your Department HR representative to ensure all requirements are met. Minor on volunteer status are not required to have a work permit.

PPE Requirements: Minors must be provided with appropriate PPE as needed based on the work activity. At a minimum, safety glasses, long pants, and close-toed shoes must be worn. Laboratory coats and other PPE deemed necessary by the hazardous materials or operations must be worn when directly working with chemicals.

Training:

1. EHS Comprehensive Laboratory Safety training must be completed by each individual prior to beginning work with any hazardous materials or operations. Visit the EHS Training webpage for dates, times, and registration information.

2. Lab-Specific Training provided by the PI must cover necessary work practices, procedures and policies to ensure that minors are protected from all potentially hazardous chemicals, biological pathogens and dangerous equipment used in the laboratory. Training on emergency procedures must also be included.

Medical Surveillance may be a requirement depending on the type of research and work activities being conducted. Examples may include respiratory protection clearance for N95’s, animal use clearance, or audiograms for noise exposure.

Consult with EHS on the need for medical surveillance
Individuals may be requested to show proof of current medical surveillance from another entity if they are visiting from an outside company or institution.

Recordkeeping:

All training must be documented and maintained in the research facility.
The approved Project Checklist and Waiver forms must be maintained by the research facility for at least two years after the minor turns 18 years old.

Emergency Procedures – All near misses, injuries, accidents, and illnesses must be reported. Appropriate medical treatment may be necessary. Determine what must be done for each minor and ensure all responsible persons are aware of the procedures.

For all incidents – Complete the EHS Incident and Near-Miss Report form and submit to EHS.
If minors are employees, complete the Illness or Injury Report form and submit to Work Connections. If medical treatment is required, follow the same procedures as employees.
If minors are not employed, they should be referred to their own physician or the nearest emergency center depending on the nature of their issue.

Technical Support

Technical support will be provided by UM-Dearborn EHS (313-583-6679), UM Risk Management Services (734-764-2200) and for UMHS, Medical Center Risk Management within the Office for Clinical Safety (734-764-4188)

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