Policy on Minors in Laboratories
Purpose
The purpose of this document is to define and clarify the policies pursuant to which minors will be allowed to access and conduct academic research in the laboratories at Boston University (BU). Except as otherwise provided in this Policy, the requirements set forth herein are in addition to those in the Protection of Minors Policy and Procedures (POM Policy). In the event of a conflict between this Policy and the POM Policy, the POM Policy requirements will prevail.
Scope
In keeping with the institution’s mission of education and outreach, BU provides opportunities to individuals under the age of eighteen (“minors”) to gain experience in research laboratories for educational purposes. This policy describes the requirements that must be fulfilled before minors, such as those participating in short term summer internship programs and other mentoring programs, will be allowed to participate in different levels of laboratory activities.
Principal Investigators or designees of the sponsoring laboratory have primary responsibility to supervise all laboratory activities and to restrict activities, as necessary, depending on the nature of materials (e.g. hazardous chemicals, radiological, biological) found in the laboratory. The goal of this policy is to help protect the health and safety of the minor and to prevent injury arising from a potential exposure to harmful agents or conditions.
Definitions
Minor
Any person who has not attained the age of 18 years.
Principal Investigator (PI)
A person designated as having the full responsibility for the oversight of a sponsored project as well as all administrative aspects, and financial and non-financial compliance aspects of the project.
BSL3
Biological Safety Level 3 which is applicable to clinical, diagnostic, teaching, research or production facilities where work is performed with indigenous or exotic agents that may cause serious or potentially lethal disease. Specific training is required for all laboratory personnel.
BSL4
Biological Safety Level 4 is applicable to facilities where work with dangerous and exotic agents that pose a high risk of infection and life-threatening disease is performed.
Select Agent Laboratory Facilities
Laboratories approved by CDC or USDA to possess, use or store biological agents and toxins classified as Select Agents under CDC 42 CFR Part 73; APHIS 7 CFR part 331 and 9 CFR Part 121.
AVP-RC
Associate Vice President for Research Compliance
EHS
Environmental Health and Safety
Areas Covered by Policy
This policy applies to all schools and departments of the university which contain “Hazardous Areas” which is understood to include:
- “Laboratories” – a research or clinical setting where scientific research or instruction is conducted in facilities in which hazardous chemicals, radiation, or biological materials are handled or stored.
- Machine rooms, electrical rooms, equipment rooms, or other rooms with unusual hazards
Individuals Covered by This Policy
This policy applies to:
- Minors who are participating in any University programs, or who otherwise have access to and are conducting research in University laboratories, including but not limited to visitors, volunteers, and interns.
- Principal investigators who are sponsoring or otherwise providing minors access to University laboratories to conduct research.
General Requirements
Permission Required
Minors are not allowed in a laboratory without written permission of Environmental Health and Safety (EHS). Requests for permission must be provided in writing to EHS using the form in Appendix A. For questions and approval processing, contact EHS at 617-638-8830, BUMC at 617-358-7840, and CRC at 617-353-4094.
Supervision
Minors must be supervised by a University faculty or staff member or student at all times in the laboratory. Supervising University faculty, staff, and students may be subject to the requirements of the POM Policy.
Access to Laboratories
Minors must be at least 15 years of age in order to be allowed access to laboratories with hazardous chemical, radioactive and biological materials for extended visits or for education-related reasons.
Touring Laboratories
Minors below 15 years of age are permitted access to laboratories with hazardous chemical, biohazard or radiation only for short-term visits, such as a high school or middle school tour of a laboratory. Adequate adult supervision must be provided at all times during the visit by the program, the department, the unit or the laboratory sponsoring the visit. Supervising University faculty, staff, and students may be subject to the requirements of the POM Policy.
Restricted Activities
- Minors under the age of 16 shall not work with, or be permitted in, a University laboratory that contains radioactive materials.
- Minors under the age of 16 are prohibited from:
- operating power driven machinery
- working with dangerous electrical machinery or appliances
- Minors under the age of 18 are prohibited to work or conduct studies or be at risk of exposure to infectious agents in the following hazardous areas:
- BSL3 and BSL4 facilities
- Select Agent laboratory facilities.
- Facilities that house or conducts procedures on research animals, unless the minor is otherwise given special permission by the Associate Vice President for Research Compliance (AVP-RC) and the Animal Facility and has completed requisite medical clearance and training requirements.
- Areas that require operation of equipment or machinery that requires specialized training, skills, or personal protective equipment, such that an individual who is not trained or skilled could incur serious injuries. Such areas may include:
- use of power-driven woodworking machines
- use of power-driven metal-forming, punching, or shearing machines
- use of hoisting machines
- Working with radioisotopes, high hazard chemicals or infectious agents or materials
- Manufacturing phosphorus or phosphorus matches
- Working with controlled substances that are regulated under the federal Controlled Substance Act and the Massachusetts Controlled Substances Act, M.G.L. c. 94C
Training
All minors must complete the Laboratory Safety Training provided by EHS prior to commencing any work in a laboratory.
Termination of Access
All minors’ access to the laboratories shall be terminated upon completion of the program in which the minor has enrolled or participated.
Requirements of the Principal Investigator/Sponsor
- Ensure that the laboratory hosting the minor(s) is in compliance with all safety policies, procedures, standards and regulations.
- Complete the “Application for Student Minors to Enter Boston University Laboratories Form” (APPENDIX A) and submit for approval.
- Ensure and verify that the “Parental Consent Form for Minors Entering a BU Laboratory Form” (APPENDIX B) has been completed and received prior to allowing the minor into the laboratory. The use of the waiver attached at Appendix B will satisfy the requirement in the POM Policy to obtain a waiver from parents/guardians of minors in a laboratory program.
- Notify appropriate oversight committees such as the Institutional Biosafety Committee (IBC) or the Radiation Safety Committee (RSC) in advance if the minor’s presence in the lab results in the addition individuals to an approved protocol.
- Ensure that the minor is directly supervised by the PI or designee at all times that the minor is on campus.
- Ensure that minors have completed the required Laboratory Safety Training by EHS prior to allowing access to the laboratory.
- Ensure that minors have been provided agent and laboratory SOP training as applicable, by the PI or designee prior to allowing access to the laboratory.
- Ensure that all University faculty and staff members and students who will be working with minors in the laboratory have met the background check and training requirements of the POM Policy prior to allowing the minor to participate in the program.
- Ensure that all University faculty and staff members and students who will be working with minors in the laboratory comply with all reporting requirements of the POM Policy while the minor is involved in the program.
- Make available and provide appropriate personal protective equipment and if appropriate, radiation film badge. (The NRC limits persons under eighteen years of age to 10% of the exposure to those eighteen years of age and older.)
Requirements of the Minor
- Provide the completed and signed Parental Consent Form for Minors Entering a BU Laboratory Form” (APPENDIX B) to the PI or sponsor.
- Complete required Laboratory Safety Training through EHS before starting any work studies in the laboratory.
- As applicable, complete the agent and laboratory SOP training provided by the PI or designee.
- Abide by and follow laboratory Biosafety Level work practices and procedures implemented in the laboratory.
- Use appropriate personal protective equipment when working in the laboratory.
- Report the accidents or injuries to the PI or designee.
- Report accidents or injuries immediately to the Research Occupational Health Program (ROHP) for evaluation and treatment at 617-358-7647.
Appendix A
Application for Student Minors to Enter Boston University Laboratories