RS101 – Minors in Laboratories

Objective

To protect the safety and health of minors on campus who are engaged in university-sponsored activities in laboratories.

Scope

This policy prohibits the presence of minors in research laboratories unless they are a university student, participating in a university-sponsored program, or hired as a university employee.

Roles

  1. The PI or designated supervisor shall:
    • Complete the Safety Assurance form attached, Appendix A.
    • Ensure minors have received appropriate site-specific training.
    • Conduct a hazard assessment for the minor’s assignments.
    • Consult with the Office of Research Safety Affairs as appropriate.
    • Ensure that minors do not participate in prohibited activities.
    • Maintain records as required under the Recordkeeping section below.
  2. Office of Research Safety Affairs shall:
    • Provide guidance to departments, supervisors, and PI regarding this procedure.
    • Develop general laboratory safety training.
    • Work with campus deans, directors, department chairs, or program managers to ensure that this procedure is disseminated.
    • Periodically review and revise this policy as necessary.
    • Maintain records as required under the Recordkeeping section below.

Definitions

Hazardous Agent – A chemical, biological, radiological material, or physical agent (e.g. noise, light, heat, etc.) capable of causing injury. This includes the “Hazardous Substance” definitions, classifications, and criteria established by 29 CFR 1910.1200 Appendix A.

Laboratory – A location where teaching, experimentation or research occurs that involves hazardous agents. Examples include, but are not limited to chemistry, biology, or other biomedical research labs. The term does not include computer labs, geography labs, or similar spaces.

Minor – Any individual under 18 years of age and not enrolled in the university as a student.

Principal Investigator (PI) – The administrative head of a research laboratory. The principal investigator determines research/work objectives, designs experiments, and assigns responsibilities to laboratory staff and students.

Supervisor – The PI or other senior individual assigned by the PI who is competent in and can reasonably oversee the research/work procedures being performed to include proper technique(s) and safety precautions.

University-sponsored program – A program meeting the requirements established in SA0575 and the HSC HR policy for Minors on Campus and approved by the department head and appropriate representative of University Administration

Policy

  • Minors are prohibited from laboratories unless they are participating in a university- sponsored program.
  • University-sponsored programs involving the presence of minors in laboratories will meet all of the requirements of UT System policies SA0575, SA0550, and the HSC HR Minors on Campus Policy and Procedures.
  • The Department Chair and Office of Research Safety will be notified in writing of any minors participating in university-sponsored programs requiring their presence in laboratories.
  • The PI or supervisor shall complete the Safety Assurance form attached, Appendix A and email a copy to the Office of Research Safety.

Hazard Assessment and Safety Assurance

The PI or supervisor shall conduct a hazard assessment of the tasks likely to be conducted by the by minor(s). Note that the Office of Research Safety is available to assist with the hazard assessment. The hazard assessment shall be documented. No minor shall be permitted to participate in prohibited activities as listed in Appendix B – Prohibited Activities. The PI or supervisor will prepare a descriptive form that describes the minor’s tasks, to be signed by the minor and the parent/guardian. A template for this form is attached as Appendix A. This descriptive form must include, at a minimum, the following:

  • A detailed description of the minor’s activities so that the minor and parent/guardian can make an informed decision about all risks associated with the proposed activity.
  • Hazard specific safety training that must be completed by the PI or supervisor with the minor.
  • Assurance that the minor will be supervised at all times while in the facility and never left alone.
  • Assurance that the laboratory/shop will be in full compliance with all applicable University safety programs and regulations.
  • Identify the PI or supervisor responsible for the minor’s activity so that minors/parents/guardians know who to contact with questions or concerns about the activity.
  • The date(s) of the proposed activity for the minors/parents/guardians to consider.
  • Clear, unambiguous language that is understandable to a layperson.
  • A release completed by each minor/parent/guardian.
  • Adequate time for each minor/parent/guardian to review the descriptive form and sign the release.

Training

A general safety orientation shall be provided and maintained by the Office of Research Safety. Minors shall take all applicable computer-based learning modules (e.g. chemical safety, biological safety, etc.) or attend in-person training before beginning work. In addition, a quiz shall be used to highlight key points and document understanding of the information. The minor’s primary supervisor or PI shall address site-specific and procedure-specific safety subjects. Subjects for this training shall be developed from the hazard assessment.

Recordkeeping

The following records shall be maintained as part of this program:

  • Training – general and specific
  • Written hazard assessment to cover any hazardous materials or associated procedures in the lab or shop (e.g. chemical hygiene plan; material safety data sheets; Institutional Biosafety Committee-approved registration documents for recombinant DNA, infectious agents, or biological toxins; standard operating procedures which address risk and risk mitigation).
  • Safety Assurance (Appendix A)

These records shall be maintained for at least three years. Records shall be kept longer in the event the minor is injured or if litigation is expected.

Responsible Official & Additional Contacts

Subject Matter

Office Name

Telephone Number

(xxx) xxx-xxxx

Email/Web Address

Policy Clarification

and Interpretation

Research Safety

Affairs

901-448-6114

labsafety@uthsc.edu

Policy Training

Research Safety

Affairs

901-448-6114

labsafety@uthsc.edu

Minors in Laboratories

Research Safety Affairs

901-448-6114

labsafety@uthsc.edu

Related Policies/Guidance Documents

SA0550-Minors in Laboratories and Shops; SA0575-Programs for Minors;

University of Tennessee Health Science Center HR Minors on Campus Policy and Procedures

Appendix A- Safety Assurance

Name of Minor Worksite Location Activity(ies)

Attach additional information if necessary

Responsible Principal Investigator or Supervisor I agree to sponsor the minor(s) identified above and by my signature below agree that:

  1. I have read, understand, and will adhere to The University of Tennessee policy on “Minors in Laboratories and Shops.”
  2. I will ensure the student has received the necessary training before participating.
  3. I have reviewed or will review with the minor at the time of arrival on campus the hazards involved with participating in the lab or shop.
  4. I have confirmed that necessary personal protective equipment appropriate for, and specific to hazards will be provided.
  5. This individual will be supervised at all times while in the laboratory or shop and never left alone.
  6. The laboratory or shop in which the minor will be working follows all applicable University of Tennessee safety programs and regulations.

Name of Principal Investigator or Supervisor:

PI/Supervisor Phone No.:

PI/Supervisor Email:

Signature:

Date:

Minor

  1. I have read, been told, and agree to follow the safety policies of The University of Tennessee.
  2. I acknowledge and agree that there are risks involved with the activity(ies) as described above.
  3. I agree to complete safety/hazard or other required training provided by The University of Tennessee Health Science Center before participation in the activity(ies) described above.
  4. I choose to voluntarily participate in this activity with full knowledge that the activity(ies) described above may be hazardous to me.
  5. I agree that my participation may be suspended at any time, at the discretion of The University of Tennessee Health Science Center and its officers, agents, and employees, if I jeopardize my own safety or the safety of others.
  6. I agree to release, indemnify, and hold harmless The University of Tennessee Health Science Center for any loss, liability, damage, or costs, including court costs and attorney’s fees, that may occur as a result of my negligent or intentional act or omission while participating in the activity(ies) described above.

I HAVE CAREFULLY READ THIS DOCUMENT AND HAD SUFFICIENT TIME TO ASK QUESTIONS AND BE GIVEN ANSWERS. I SIGN THIS DOCUMENT VOLUNTARILY.

Name of Minor (print):

Signature:

Date:

Parent/Guardian

I, , (PRINT NAME) am the parent or legal guardian of the participant who has signed above.

  1. I have read and understand what my child will be doing and the risks involved.
  2. I understand that I may contact the PI or supervisor if I have questions or concerns.
  3. I agree that my child’s participation may be suspended at any time, at the discretion of The University of Tennessee and its officers, agents, and employees, if the safety of my child or others becomes a concern.
  4. I certify my child has adequate health insurance necessary to provide for and pay any medical costs that may directly or indirectly result from my participation in the activity(ies) described above.
  5. I have read and I understand this information and I consent to my child taking part in the activity(ies) described above, and I fully enter into and agree to the above Assumption of Risk and Release from Liability set forth above.

Name of Parent or Guardian (print):

Signature:

Date:

Appendix B – Prohibited Activities

The follow list of activities shall not be undertaken by minors:

  1. Hazmat Spills – Clean up spills of hazardous materials.
  2. Handling highly hazardous chemicals – These include chemicals which may be highly flammable (Class IA) or explosive, may have extremely unfavorable health implications, or possess a significant risk larger than the intended academic benefit.
  3. Handling open sources of radioactive materials, exposure to x-ray machines, or being left unattended with any type of ionizing radiation. Exposure to noise sources exceeding 90 dBA.
  4. UT Vehicles – Operation of UT vehicles, including all-terrain vehicles, motorcycles, carts, and any other motorized or electric conveyances.
  5. Non-ionizing Radiation – Exposure to laser in hazard classes III or IV; exposure to nonionizing radiation sources exceeding standards established by the American Conference of Governmental Industrial Hygienists.
  6. Ionizing Radiation – Handling any materials or equipment producing ionizing radiation.
  7. SCBA – Presence in situations where a self-contained breathing apparatus is necessary.
  8. IDLH – Presence in situations that are considered immediately dangerous to life and health as defined by the National Institute for Occupational Safety and Health (NIOSH).
  9. Imminent Danger – Presence in situations that are considered an imminent danger.
  10. Lockout/Tagout – Equipment maintenance, set-up, repair, adjustment or testing that would require lockout/tagout.
  11. Construction Sites – Presence on construction sites.
  12. Scaffolding – Presence on scaffolding more than 10 feet above the ground.
  13. Any other activities that the Commissioner of Labor and Workforce Development has declared by regulation to be hazardous or injurious to the life, health, safety, and welfare of minors.

RS101 – Minors in Laboratories
Version: 2 // Effective: 05/13/2024
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