G.1.27 Minors in Research Laboratories and/or Other Research Activities

Marine Biological Laboratory
Policy No. G.1.27
Human Resources

Initiated by:                 Environmental Health & Safety Manager
Approved by:               Director of the Division of Research
Date:                           January 16, 2018
Distribution:                All MBL Supervisors

1.0       Purpose

The Marine Biological Laboratory (MBL) is committed to providing a safe and healthy environment for minors who participate in programs and activities at MBL. This policy is intended to provide guidelines to Principal Investigators (PIs), Departments, Centers and Divisions and other supervisors on the health and safety requirements for minors participating in an MBL sponsored educational activity or paid work assignment occurring within research laboratories.

2.0       Policy

PIs and supervisors have a fundamental responsibility and accountability to ensure the safety of all minors in research laboratories. Therefore minors are permitted in research laboratories only in the circumstances outlined below:

    2.1 Minors (including minor children of laboratory personnel) are permitted in research laboratories under any of the following conditions:

•         They are participating in an MBL sponsored event, such as an organized tour of laboratory facilities, at a time during which no active research involving hazardous materials is underway, or
•         They are in designated laboratory areas which do not contain hazardous substances or hazardous machinery, or
•         They are being escorted to/from an enclosed office/breakroom within a laboratory.

    2.2       Minors participating in an approved Science Fair Project or Educational Program are permitted in research laboratories under the following conditions:

•         The minor or Educational Program supervisor must provide documentation of school consent to perform activities at MBL.
•         All persons directly supervising minors must have a Criminal Offender Record Information (CORI) background check on file in the Human Resources (HR) Department (or in place with supporting institution). Note that currently, CORI background checks are valid for two years and a new background check may take up to 3 weeks.
•         Minors must be directly supervised at all times while in a research laboratory. For a Science Fair Project the supervisor must be the PI or a person over 21 years of age designated in writing by the PI.  For an Educational Program the supervisor must be over 21 years of age and designated in writing by the educational program supervisor.
•         Minors are not permitted access to laboratories unless they wear clothing appropriate for the educational activity and work environment, as specified by the PI or educational program supervisor.
•         The PI or educational program supervisor must ensure that minors use appropriate personal protective equipment (PPE) in the correct manner when working in a research laboratory.
•         The PI or educational program supervisor must ensure minors receive appropriate safety training by the PI or MBL Safety Office.

    2.3       Minors of age 16 and 17 may be employed by the MBL or participate in research at the MBL as an intern.  Minor employees or interns may access research laboratories under the conditions described in Sections 2.2.2 –2.2.5, and under the following additional conditions:

•         At least two weeks prior to activity by the minor in a laboratory the PI must submit a Proposal for an Assignment of a Minor in a Laboratory form (Appendix A).
•         The minor must receive appropriate safety training by the MBL Safety Office.
•         All laboratory specific training provided to the minor must be documented and retained by the Principal Investigator.

    2.4       Minors are prohibited from working with the following hazardous materials or in the following hazardous environments:

•         Working in an area with Select Agents;
•         Working in an area or performing activities requiring the use of a respirator;
•         Handling Risk Group 3 pathogens;
•         Operating Class 3B or Class 4 Lasers;
•         Handling radioactive substances;
•         Working with substances present on the OSHA particularly hazardous substances list;
•         Operating Autoclaves.

    2.5       Minors are restricted* when working with the following hazardous materials or in the following hazardous environments:

•         Performing work involving the handling or storage of blood, blood products, or body fluids or tissues;
•         Handling Risk Group 2 organisms;
•         Working with carcinogens, teratogens, or mutagens;
•         Working with live animals;
•         Operating power tools or machinery.

    *Appropriate training and supervision must be provided prior to these activities being initiated.

3.0       Definitions

Educational Activity:  A structured learning opportunity for a minor with a defined and reasonable set of goals, mentored oversight, and is for the benefit of the minor and not others.

Educational Assignment: An Educational activity that requires personal initiative by the minor and takes the form of an internship or employment.

Minor:  A minor is a person under the age of eighteen.

Research Laboratory:  An area where hazardous substances, such as chemicals, biological materials, radiological materials, and/or lasers are commonly used. Additional hazards, such as high voltage power supplies, high power lasers and other equipment or process hazards may be present.

Supervisor:  A PI, supervisor or technician who provides continual instruction and oversight of the minor in a laboratory with hazardous substances or hazardous machinery.

Intern:  Refer to Policy No, G.1.26, Intern and Volunteer for definition.

4.0 Additional Guidance

    4.1 The MBL does not intend for minors on educational assignments to perform or displace work that is presently being performed by MBL employees. Likewise, educational assignments may not be used to circumvent the established processes that govern standard authorized hires.

    4.2 This policy does not apply to general public events where parents and guardians are invited and expected to provide supervision of minors or to events where parents and guardians are explicitly required to accompany their children. 

5.0 Incident Reporting

Any incident or accident involving a minor must be reported to Human Resources, Environmental Health and Safety, and the minor’s parent/legal guardian within 24 hours. The incident must be recorded on MBL’s Accident/Injury Report. Reports will remain on file with HR.

    5.1       Medical Treatment

•     The minor’s parent or guardian is responsible for the cost associated with any medical treatment provided as the result of a laboratory illness or injury.
•     Non-serious injury/illness:  Treatment should be coordinated by the minor’s personal care provider.
•     Serious injury/illness:  Treatment shall be immediately arranged at local walk-in care facility or local hospital emergency department. 

6.0       Consequences of Non-Compliance

Violations of this policy by PIs or supervisors may result in termination of the minor’s educational activity and discipline of the PI/supervisor, including termination of PI’s or supervisor’s privilege to have minors work in laboratories as reviewed by the Director of the Division of Research and the Director of Human Resources.

Minors are expected to comply with MBL polices, and may have their educational activity modified or terminated for the following: violating this policy; violating supervision rules; failure to use appropriate PPE; failure to wear appropriate clothing for laboratory work; failure to satisfactorily perform the educational activity.

Consequences for violation of this policy shall depend upon the severity of the violation and can be in the form of a verbal warning, a written reprimand and warning, along with a notice sent to the parent or guardian or termination of the educational activity.