Environmental Health and Safety

Requirements for Minors Performing Laboratory Research

Scope

This policy governs the presence of minors (individuals under 18 years of age) in any Reed College laboratory or shop that uses hazardous chemicals, biohazardous or infectious materials (any work above BSL1), radioactive materials or radiation-producing equipment, or where there are physical hazards including (but not limited to) compressed gasses, high voltage, extreme temperatures, excessive noise, lasers, or heavy machinery.

This policy applies to all minors involved in summer internships, volunteering in research projects, and participating in scheduled assignments in a laboratory setting.

The policy does not apply to students enrolled in courses listed in a campus course catalog having a laboratory component or in Reed College’s Science Outreach program.

Restrictions by age group

• Minors under the age of 18 are not allowed in Reed College vivaria unless their participation has been reviewed and approved by the Reed College Institutional Animal Care and Use Committee (IACUC) and the responsible vivarium facility manager based upon criteria established by the campus.
• Minors under the age of 18 are never permitted in any setting where research involving controlled substances, radioactive materials, recombinant DNA, lasers, uncontrolled heights above 4ft, or heavy machinery is being performed.
• Minors are prohibited from using the following equipment: autoclaves, microtomes, cryostats, anaerobic chambers, ultracentrifuge, lasers, and rotary evaporators. Minors may engage in observation-only activities with this lab equipment.
• Vehicles and forklifts are also restricted from minors' use.

Requirements for Minors Performing Research

Faculty, before you permit minors to perform research activities in your laboratory, you must obtain authorization and observe specific restrictions and procedures.

Written Authorization

Obtain written authorization before the minor begins scheduled assignment in the lab that uses hazardous chemicals, biohazardous or infectious materials (any work above BSL1), or where physical hazards include (but are not limited to) compressed gasses, high voltage, extreme temperatures, excessive noise, or lasers. This policy applies to all minors involved in summer internships, volunteering in research projects, and participating in a scheduled assignment in a laboratory setting.

1. Request authorization by completing the Hazard Review Form for Minors Performing Research in Laboratories :

• Describe project, designate a qualified adult laboratory supervisor, and obtain written authorization from the PI, supervisor, minor, and minor’s parent/guardian.
• Review the minor’s responsibilities in the lab.
• Obtain signatures of both the minor and the parent/guardian.

At this time, you should obtain Release, Waiver and Indemnity authorization from the minor’s parent/guardian. 

2. Send the completed documents to EH&S via email to ehs@reed.edu.
3. EH&S will review the forms. If approved, EH&S will return the approval letter with the original hazard review form to the Faculty Supervisor, authorizing the minor to enter the lab. Please allow 2 weeks for EH&S to review submitted documents. If EH&S has any questions, you will be contacted for hazard clarification. 
4. Keep the approved letter and form in your departmental files for 3 years.
5. Submit approval letter with Faculty issued award letter to Business Office to issue payment, if applicable. 

Note: Only minors working with hazards present in the lab are required to complete the Hazard Review Form.

Supervision

Never allow the minor to work alone.

• Provide direct supervision of the minor in the laboratory environment by a qualified adult laboratory supervisor at all times. "Direct supervision" means the following: 
  • The minor is accompanied into the lab by a trained and knowledgeable supervisor who is designated on the Hazard Review Form for Minors Performing Research in Laboratories (see above).
  • The designated supervisor must be the actual person observing and physically present in the lab with the minor. 
  • If under exceptional circumstances and the primary supervisor cannot be present, an alternate supervisor, formally named on the Hazard Review Form for Minors Performing Research in Laboratories, may substitute. 

Safety Training and PPE

• Confirm the minor receives appropriate laboratory safety training: 
  • Explain hazards specific to your lab, equipment, and the materials the minor may use.

• Show the minor how to access and understand Safety Data Sheets (SDSs).
• Explain possible routes of exposure, as appropriate (skin absorption, ingestion, inhalation, etc.) and precautionary measures to limit exposures.
• Evaluate each potential hazard present in the work environment (e.g., compressed gasses, high voltage, extreme temperatures, excessive noise, lasers, etc.) the minor may encounter and:
  • Review the potential hazards.
  • Review safe operating procedures for the equipment.
  • Review emergency procedures for the equipment.
  • Establish specific and explicit written instructions (Standard Operating Procedures) for the work the minor is allowed to perform.
• Provide appropriate personal protective equipment (PPE) and engineering controls, and train the minor in their proper use.

Emergency Procedures

Instruct the minor on emergency procedures.

• Review emergency procedures with the minor:
  • Building exits
  • Where to assemble outside in case of building evacuation
• Show the minor where emergency equipment is and how to use it:
  • Telephone and emergency phone numbers
  • First-aid kit
  • Eyewash and emergency shower
  • Fire alarm pull stations and fire extinguishers*

* Notice: In case of fire, your first responsibility is to escape unharmed and sound the alarm. Use a fire extinguisher only if you have been trained to use one and you have a clear exit path behind you.