Environmental Health and Safety

Requirements for Minors Performing Research

Principal Investigators - follow these steps to get University of Michigan - Dearborn authorization and parental permission for a minor to participate in independent research activities and to meet supervision, training, and hazardous materials requirements and restrictions. Read EHSEM's Visitors and Volunteers to University of Michigan - Dearborn Laboratories Guideline which gives details on age restrictions and the principal investigator's responsibilities.

*The scope of this policy does not include university-sanctioned programs for the introduction of high-school students to the sciences, where minors are closely and continuously monitored by instructional staff. Examples include summer science camps and related outreach programs held during the academic year. Such programs do not constitute independent research activity.

1. Get authorization before the minor enters the lab

Request authorization by submitting the 2 forms below:

Send copies of both completed forms mentioned above to EHSEM by fax at (313) 436-9161. Keep the approved original forms in your departmental files.

In addition to complying with EHSEM requirements of minors performing in research, principal investigators are responsible for understanding a complying with the University's policies on volunteers and employment. Please review the following policies:

If you have any questions regarding your ability to have a minor volunteer or work in your research lab, please consult with your department's Human Resources Representative.

2. Ensure supervision requirements are observed

Minors are prohibited from working alone in UM-Dearborn laboratories.

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 Project Checklist form.
  • The designated supervisor must be the actual person observing and physically present in the lab with the minor.
  • If under exceptional circumstances the primary supervisor can't be present, an alternate supervisor, formally named on the Project Checklist, may substitute.

3. Instruct the minor on emergency procedures

Review the University of Michigan - Dearborn Emergency Flip Chart with the minor. Show the minor the following emergency equipment and locations:

  • Telephone and emergency phone number's for DPS (911 from a campus phone or 313-593-5333 from a cell phone)
  • First-aid kit
  • Eye wash and emergency shower
  • Fire alarm pull stations and fire extinguishers
  • Building exits - means of egress signs posted
  • Site assembly area

4. Provide general laboratory safety training

Make sure the minor receives appropriate laboratory safety training:

  • Begin my enrolling the minor in EHSEM's General Lab Safety Training.
  • Receive a copy of the certificate of training given by EHSEM to document the training.
  • Keep all safety training documentation in the laboratory's personnel training files.

Explain hazards specific to your lab, equipment, and the materials the individual will work with:

  • Show the minor how to access and understand Safety Data Sheets (SDS) for the chemicals they will work with. If SDS is not available check the UM SDS database.
  • Explain possible routes of exposure, as appropriate:
    • Skin absorption
    • Ingestion
    • Inhalation
    • Penetration

Provide personal protective equipment (PPE), explain safe use of chemical fume hoods and biological safety cabinets, and train the minor in their proper use.

5. Observe hazardous materials restrictions and safety training requirements

Follow these restrictions and safety training requirements:

CHEMICAL SAFETY:

BIOLOGICAL SAFETY:

Restrictions for working with potentially biohazardous substances depend on age group:

  • Minors between the ages of 12 and 16:
    • Are prohibited from working with biohazardous materials above biosafety level 1 (Risk Group 1 agents using BSL-1 practices and precautions).
    • May enter and work at BSL-1 in a large open-bay laboratory where BSL-2 work may be taking place, providing they have no contact with the BSL-2 work.

  • Minors between the ages of 16 and 18:
    • Are prohibited from working with biohazardous materials above biosafety level 2 (Risk Group 2 agents using BSL-2 practices and precautions).
    • May enter and work at BSL-2 with appropriate training and medical surveillance (if applicable)

  • Training
    • Minors permitted to work at BSL-2 must receive job specific training from the responsible PI.
      • PI's must use the laboratory's Biosafety Manual to instruct the minor on the risk assessment and safe handling SOP's developed for the RG2 agents in use.
      • PI's must instruct the minor in proper handling and disposal requirements for biohazardous waste.
    • Minors must be provided with appropriate medical surveillance and training, if applicable.
    • If work will involve human blood, body fluids, or tissues, the laboratory's Exposure Control Plan requires that the minor and their parent or guardian be offered the Hepatitis B immunization at no cost, or the parent or guardian must sign a declination form.

RADIATION SAFETY:

  • Restrictions: Minors are generally prohibited from handling radioactive materials.

ANIMAL USE:

  • Restrictions: Minors are generally prohibited from handling research animals.