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Assistant Director of Laboratory Safety & Chemical Hygiene Officer Email 401-863-7697

Policy on Minors in Laboratories

Policy No. Issue Date Effective Date
11.05.02

1.0 Policy Purpose

This policy defines when and under what conditions Minors are allowed to enter Brown University research laboratories, laboratory support spaces, workshops, art studios and teaching laboratories (individually a “Laboratory” and collectively the “Laboratories”).

2.0 To Whom the Policy Applies

This policy applies to Minors in Laboratories. It does not apply to undergraduate students in teaching laboratories, computer laboratories, clinical settings, or interview rooms.

3.0 Policy Statement

Minors under age 16 are prohibited from entering Laboratories, except for certain events and tours provided for in Section 3.3 of this policy. Minors ages 16 and 17 are permitted to enter Laboratories under the terms and conditions of this policy.

3.1 Task & Area Restrictions

3.1.1 Minors ages 16 and 17 may not enter Laboratories where the following potential Hazards exist:

  • Class 3b or 4 Lasers;
  • Explosive Chemicals;
  • Radiation Exposures (radioactive materials, x-ray);
  • Risk Group 3 & 4 Agents;
  • Hazardous machines, such as band saws, circular saws, power saws, lathes, welding equipment (including Machine Shops) unless approved in writing by the Office of Environmental Health & Safety (EHS);
  • Animal work or lab areas where animal research is being conducted unless approved in writing by the Center for Animal Resources and Education and EHS.

3.1.2 Minors ages 16 and 17 may not enter Laboratories while the following potential Hazards are being handled:

  • Blood Borne Pathogens;
  • Biological Toxins and Select Agents;
  • Risk Group 2 Agents;
  • Reactive Chemicals;
  • Carcinogens;
  • Reproductive Hazards;
  • Acutely Toxic Hazards;
  • Power Tools.

EHS may grant exceptions to Section 3.1.2 when engineering controls such as fume hoods and biological safety cabinets are utilized while the Minor age 16 or 17 is present. Any approval granted must be in writing.

3.1.3 Minors ages 16 and 17 must never handle Hazardous Waste.

3.2 Training and Supervision

  • Minors ages 16 and 17 must be supervised at all times. The person(s) assigned to supervisory duties must be current in all required relevant safety training based on the Hazards in the area.
  • Minors ages 16 and 17 must complete applicable safety training prior to entering any Laboratory. Training requirements will be available to the Minor online, but classroom attendance is strongly recommended when the trainings are offered in person.
  • EHS must be contacted to review and approve the work that will be performed by the Minor at least 30 days before the Minor is scheduled to be present in the Laboratory. The Minor’s supervisor must fill out the Minor Form and return it to the University Chemical Hygiene Officer.
  • Minors ages 16 and 17 who are employed by Brown University must comply with all requirements for being employed on the limited duration payroll, including, but not limited to, completing an I-9 within 3 days of hire and adhering to all policies applicable to limited duration employees.
  • Minors ages 16 and 17 who are interns or volunteers (unpaid) are not considered Brown employees. A completed parental release and consent form for these Minors must be submitted to the University Chemical Hygiene Officer (labsafety@brown.edu) prior to the Minors entering any Laboratory.
  • Minors must follow all Personal Protective Equipment (PPE) requirements for the area they will be in and the activities they will engage in. This includes wearing long pants, closed toe shoes, and impact safety glasses. EHS has the right to remove and terminate approved access from the Minor if all PPE requirements are not being followed.

3.3 Events and Tours

Minors ages 10-17 may enter Laboratories as part of organized University-approved events for a national or state organization, career or technical education program, or as part of an organized tour for education, admission, and recruitment purposes. Tours must be conducted with permission of the Supervisor responsible for the Laboratory and the Department Chair or the Chair’s designee. Any work with Hazardous Materials or Hazardous Equipment is prohibited during the event or tour unless EHS authorizes such use in writing and only for demonstration purposes. Hazardous Materials not being used must be properly stored. The department and/or the Supervisor that will be conducting the tour or event is responsible for proper supervision and providing appropriate PPE for visitors including, eye protection devices. All personnel that will be supervising Minors for these types of events must have completed Laboratory Safety Training, Hazardous Waste Training, and/or other required applicable training. Minors must be supervised by a Supervisor or Designated Supervisor at all times while in the Laboratory. Minors 9 years of age and younger are prohibited from entering Laboratories under any circumstance.

4.0 Definitions

For the purpose of this policy, the terms below have the following definitions:

Designated Supervisor:

The Brown employee who is assigned by the Supervisor to supervise the Minor(s) in specific circumstances or during specific events. The Designated Supervisor must be current in applicable safety training.

Hazardous Equipment:

Equipment which poses a risk to humans and/or the environment and can cause injury or death.

Hazardous Materials or Hazards:

Any material or substance (chemical, biological, radiological) that poses a physical or health risk capable of causing negative effects on the health and safety of humans, animals, or the environment. This includes but may not be limited to Hazardous Materials or substances regulated by the Department of Transportation (DOT), Occupational Safety and Health Administration (OSHA), and/or Environmental Protection Agency (EPA).

Hazardous Waste:

A chemical substance or chemical product that is no longer intended or viable to use for work, research, or academic purposes and meets specific criteria established by the Environmental Protection Agency or the RI Department of Environmental Management.

Minor:

A person under the age 18.

Supervisor:

The University employee individual with final responsibility for the conduct of research or work and overall safety within the Laboratory. In research laboratories, this individual may be the Principle Investigator, Laboratory Supervisor or PI on the Research that involves the use of Hazardous Materials and is typically a faculty member.

5.0 Responsibilities

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University Supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.

Supervisor: The responsibilities of the Supervisor include the following:

  • Ensure that Brown University Human Resource approvals and work conditions are followed with regards to Minors who are employees.
  • The Minor Form is completed and is submitted to the University Chemical Hygiene Officer and approved before a Minor may perform any work in a Laboratory.
  • The Minor Volunteers in Laboratories Assumption of Risk and Release Agreement form is completed and is submitted to the University Chemical Hygiene Officer.
  • Ensure Minors are supervised at all times while in Laboratories.
  • Ensure Minors are not working with restricted materials as outlined in this policy.
  • Ensure Minors are wearing appropriate PPE at all times while in Laboratories.

Designated Supervisor: The responsibilities of the Designated Supervisor include the following:

  • Ensure Minors are supervised at all times while in Laboratories.
  • Ensure Minors are not working with restricted materials as outlined in this policy.
  • Ensure Minors are wearing appropriate PPE at all times while in Laboratories.

Minor: The responsibilities of the Minor include the following:

  • Complete all required safety training prior to the first day of assignment.
  • Follow all PPE requirements for the area they will be in.
  • Ensure all required forms, documents, and other information has been timely submitted to Brown.

EHS: The responsibilities of EHS include the following:

  • Review submitted Minor Form to ensure Minor is not working with restricted materials as outlined in this policy and to approve the activities as appropriate.
  • Review training needs, assign applicable training, and ensure training completion status of both the Minor and Designated Supervisor.

6.0 Consequences for Violating this Policy

Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures or for non-employees may result in the suspension or revocation of the user’s relationship with Brown University. Additionally, failure to comply with this policy will result in the removal of the Minor from the area.

7.0 Related Information

Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).

The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.

7.1 Related Policies

7.2 Related Procedures

N/A

7.3 Related Forms

7.4 Frequently Asked Questions (FAQs)

N/A

7.5 Other Related Information

Policy Owner and Contact(s)

Policy Owner: Executive Vice President for Finance and Administration

Policy Approved by: Executive Vice President for Finance and Administration

Contact Information:

Assistant Director of Laboratory Safety & Chemical Hygiene Officer Email 401-863-7697

Policy History

Policy Issue Date:

Policy Effective Date:

Policy Update/Review Summary:

Policy format changed to the University standard. Included “workshops and art studios”, changed pathogens to agents, changed BSL-2 agents to Risk Group 2 Agents, replaced Laboratory Supervisor with Supervisor, and updated form requirements. Previous policy versions superseded by this policy:

  • Policy on the Presence of Minors in Research Buildings, Revised Date: January, 2019
  • Policy on the Presence of Minors in Research Buildings, Revised Date: September, 2018
  • Policy on the Presence of Minors in Research Buildings, Revised Date: September, 2008