The information below is intended to provide guidance to Principal Investigators or Laboratory Supervisors on the health and safety requirements for minors participating in the University-sponsored function of laboratory research. A minor is a person under 18 years of age, including registered students at Stanford University. Because of their relative lack of experience in recognizing hazards, restrictions are placed on minors working in laboratories to ensure a safe research experience. Review the state of California's existing labor laws [1] and Stanford University's policies on the Protection of Minors [2] and Recruiting and Hiring of Regular Staff [3] to learn more about these restrictions. These requirements and restrictions apply whether the minor participates as a volunteer, employee, or registered student at the University.
Supervision
The Principal Investigator (PI) is responsible for the health and safety of minors working in his or her laboratory. This includes the provision for and enforcement of the correct use of engineering controls, work practices, and personal protective equipment.
The PI may delegate daily supervision of minors to trained and knowledgeable lab personnel, but the PI retains primary responsibility. Minors may only work in labs under direct supervision, either by the PI or designated lab personnel. Minors may not be alone in the lab. Minors are not permitted to have their own building and laboratory access.
Training
Minors working in laboratories are required to complete all appropriate safety training before beginning lab work. The PI is responsible for ensuring that minors are trained appropriately.
General laboratory training
Online safety training is available through the STARS training tab in the Axess portal [4] and requires a sponsored SUNet ID. All minors working in laboratories must complete the following online courses:
- EHS-4200 – General Safety & Emergency Preparedness
- EHS-1900 – Chemical Safety for Laboratories
Depending on additional potential hazards and/or department-specific requirements, other online safety courses may be required. Consult your home department for guidance.
Lab-specific training
Qualified lab personnel must provide lab-specific training for minors. This training includes a review of the specific hazards (e.g. chemical, biological, radioactive, physical, etc.) that exist in the lab, as well as the procedures, equipment, and resources available for working safely with these hazards. Training must be provided for all personal protective equipment the minor will encounter. For additional guidance, see How to Develop Lab-Specific Training [5].
Documentation
The PI must document and retain all lab-specific safety training provided to minors for at least one year.
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Restricted Activities
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Restricted Areas
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Incident Reporting
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Medical Treatment
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If the proposed research for a minor includes a restricted activity described below, contact the Occupational Health & Safety Program at (650) 723-0448 for more information.
Biohazardous materials
Activities that are not allowed:
- Entering a biosafety level 3 (BSL-3 [6]) lab or working with materials that are BSL-3 [6]
- Working with select agents or toxins [7]
Additional requirements:
- Minors working with biosafety level 2 (BSL-2 [6]) materials must be approved on the relevant protocol with the Administrative Panel on Biosafety [8] and must have their minor status disclosed.
- If minors will be working with human blood, body fluids, or tissues, including tissue culture, they must receive pre-placement medical evaluations from their personal care provider. A Hepatitis B Vaccine Status Form for Minors [9] must be submitted to the Stanford University Occupational Health Center before starting work.
- For questions, the physician may contact the Occupational Health Center at (650) 725-5308.
Chemicals
Activities that are not allowed:
- Working with restricted chemicals [10], controlled substances [11], select carcinogens [12], reproductive toxins [13], highly toxic chemicals [14], or highly reactive materials [15].
Lasers
Contact Health Physics at (650) 723-3201 if the proposed research involves lasers. Depending on the class of laser used, a baseline laser eye exam may be necessary.
Packaging and shipping of hazardous materials
Activities that are not allowed:
- Packaging and shipping of biological samples, chemicals, dry ice, and radioactive materials
Radioactive materials or radiation-emitting machines
Activities that are not allowed:
- Working with or around radioactivity if the occupational exposure exceeds an annual dose of 100 mrem
Additional requirements:
Contact Health Physics at (650) 723-3201 if the proposed research involves radioactivity.
Research animal contact and work
Activities that are not allowed:
- Risk Category 1 (RC1) [16] work, which includes work with non-human primates (including unfixed tissue and bodily fluids), hoofed mammals (e.g., swine, goats, sheep, cows), wild rodents, and certain field studies
Additional requirements:
- Minors must be listed on the relevant protocol with the Administrative Panel on Laboratory Animal Care (APLAC) [17] and have their minor status disclosed.
- Minors must be medically cleared by their personal care provider before beginning Risk Category 2 (RC2) [16] work, which includes animal work that does not fall within the RC1 category.
- A medical clearance form [18] signed by their personal care provider must be kept on file with the PI or the PI’s home department.
- For questions, the physician may contact the Occupational Health Center at (650) 725-5308.
Spills involving hazardous materials
Trained minors may only clean up spills [19] under direct supervision by trained and knowledgeable lab personnel.
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Minors are prohibited from being present in work areas at Stanford University except as outlined below. Although there may be emergency situations when faculty, staff, or students do bring a child to work on a limited, short-term basis, the supervisor must be informed in advance and, if she or he approves, adequate steps must be taken to prevent injury or disruption to others at work.
It is especially important that younger children be restricted from hazardous work areas due to their developing immune/neurological systems and their general lack of hazard recognition ability. We also recognize there may be times when minors may be invited to University sponsored events (i.e. Take Your Children to Work Day). However, certain attention should be given to work areas where hazardous material or equipment is located, as noted below.
A potentially hazardous work area is an area where hazardous substances (i.e., hazardous chemicals, biohazardous agents, radioisotopes) and/or physical hazards (e.g., radiation, lasers, moving machinery parts, extreme temperatures, electrical apparatus) are present.
Persons under 18 years of age are not permitted in potentially hazardous work areas within Stanford University (e.g. laboratories, shops, and other potentially hazardous work areas), except when all of the following criteria are met:
1. Passing through the potentially hazardous work area (e.g., to reach an office area):
- A University staff member who is trained and knowledgeable of the area’s potential hazards escorts minor directly to the destination.
- Minor is protected from potential hazards as deemed appropriate by the area supervisor.
OR;
2. Briefly touring the potentially hazardous work area (e.g., class tours, parent showing work area to child/minor):
- Parent/Legal Guardian/School obtains approval from the Principal Investigator, Operations Manager, or the Manager with equivalent responsibility for area to be toured.
- Minor is personally accompanied at all times by University staff member who is trained and knowledgeable of the area’s potential hazards.
- The trained University staff member ensures that the minor is NOT placed into a situation where he/she may endanger the health and safety of self or others.
- Minors are provided appropriate personal protective equipment.
- For group tours, a safety briefing is provided to the group prior to entry to the area.
OR;
3. Participating in a University-sponsored function that requires more than intermittent presence in the work area (e.g., course work in a lab, conducting research, etc.):
- Parent/Legal Guardian obtains approval from the Principal Investigator, Operations Manager, or the Manager with equivalent responsibility.
- The host department has a signed Parental/Legal Guardian Consent on file for the minor. Minor is under the direct supervision from University staff member who is trained and knowledgeable of the area’s potential hazards.
- Minor is provided appropriate safety training:
- General Safety (including emergency procedures and personal protective equipment).
- Site-specific safety training (i.e., chemical safety, radiation safety, blood borne pathogens). Consult with supervisor.
- Minor is provided appropriate personal protective equipment.
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Any incident or accident involving a minor (e.g. chemical exposure, needle stick injury, animal bite or scratch, etc.) must be reported to the PI immediately.
Documentation
The minor must complete an Incident Investigation Report Form [20], under guidance from the PI, to document the incident. This form must be signed by the PI and a copy faxed to Risk Management as soon as possible, but no later than 24 hours after the incident.
Notifications
The PI must immediately notify his or her home department of any lab-related incident involving a minor. Immediately after departmental notification, the PI or home department must notify the minor’s parent or legal guardian.
Cal/OSHA reportable injury/illness
Call the EH&S Emergency Hotline at (650) 725-9999 immediately so that EH&S can report the incident to Cal/OSHA. Reference Serious Injury/Illness Reporting Procedures [21] for additional guidance.
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The minor’s parent or legal guardian is responsible for the cost of any medical treatment provided as the result of a lab-related injury or illness that is not covered by workers’ compensation insurance. Contact your home department for more information.
Serious injury or illness
Treatment shall be immediately arranged at Stanford Hospital Emergency Department or at the nearest available emergency department.
Non-serious injury or illness
Treatment should be coordinated by the minor’s personal care provider. For questions or consultation, the provider may contact the Stanford University Occupational Health Center at (650) 725-5308.