Requirements for Minors Performing Research

• Request authorization by submitting the 2 forms below:
  • Form 1: Print out and complete a Proposed Project Checklist for Minors Performing Research in Laboratories (PDF) form. On the form:
    • Describe the project.
    • Obtain written consent from the minor's parent(s) or guardian.
    • Designate a qualified adult laboratory supervisor and an alternate supervisor, if necessary.
  • Form 2: Print out and complete a Waiver of Liability, Assumption of Risk, and Indemnity Agreement (PDF) form.
    • Obtain signatures of both the minor and their parent or guardian on the waiver.
    • Keep the original waiver in your deparmental files for 2.5 years after the minor turns 18 years old.
• Send the original completed Project Checklist form and a copy of the waiver to:
  • EH&S Research Safety Manager (RSM)
    Mail Code 0089
  EH&S will return the approved (signed) original form to the PI, authorizing the minor to enter the lab.
• Keep the approved original form in your departmental files.

Never allow the minor to work alone.

• 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.

• Review UCSD's Emergency Guide with the minor.
• Show the minor the following emergency equipment and locations:
  • Telephone and emergency phone numbers
  • First-aid kit
  • Eye wash and emergency shower
  • Fire alarm pull stations and fire extinugishers
  • Building exits
  • Where to assemble outside in case of building evacuation

• Make sure the minor receives appropriate laboratory safety training:
  • Complete a New Worker Checklist (PDF) before the minor begins work.
  • Keep all safety training documentation in the lab's files.
• Explain hazards specific to your lab, equipment, and the materials the individual will work with:
  • Show the minor how to access and understand material safety data sheets (MSDSs) for the chemicals they will work with. Read Material Safety Data Sheets (MSDS) Explained.
  • Explain possible routes of exposure, as appropriate:
    • Skin absorption
    • Ingestion
    • Inhalation
  • Provide personal protective equipment (PPE) and engineering controls, and train the minor in their proper use.

• Follow these restrictions and safety training requirements:
  • Chemical safety:
    • Restrictions
      • Minors are not allowed to work with:
        • Acutely hazardous materials (i.e., compounds having a rat oral LD50 less than or equal to 50 mg/Kg, such as hydrofluoric acid, acrylonitrile, osmium tetroxide, etc.)
        • International Agency for Research on Cancer (IARC) Group 1 or 2A carcinogens or Cal/OSHA-regulated carcinogens
    • Training
      • Follow the General Chemical Safety Guidelines.
      • Make sure the minor attends Laboratory Safety Principles/ Injury & Illness Prevention Program training prior to direct work with chemicals.
  • Biological safety:
    • Restrictions
      • 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 (BSL-1)
          • 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 BSL-2
          • 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, including biohazardous waste handling instruction.
      • PIs may also decide to develop a tiered level of training, confirming competency at each level before going to the next level of difficulty or increased hazard.
      • If work will involve human or primate blood, body fluids, or tissues, the minor and their parent or guardian must:
        • Contact UCSD Occupational Health and Environmental Medicine (COEM), (619) 543-7060, to be counseled by a healthcare provider regarding health risks
        • Be offered the Hepatitis B vaccine at no cost, or the parent or guardian must sign a declination form
        • Be provided with appropriate medical surveillance and training, if applicable
        • Follow UCSD Animal Care Program policies if working with laboratory animals
  • Radiation safety:
    • Restrictions:
      • Minors generally are not allowed to work with or handle radioactive materials or radiation-producing machines. PIs may apply for an exception to allow a minor to work under direct supervision with up to 1 mCi per experiment.
        • Apply to the radiation safety officer (RSO) for exceptions.
      • Minors are not allowed under any circumstances to work with the following materials:
        • Inorganic P-32 orthophosphate
        • Volatile forms of radioactive iodine
        • Irradiators
        • Radiation-producing machines
    • Training
      • Minors working with eligible radioactive materials must:
        • Attend Radiation: Safety Seminar
        • Get additional training if required by the RSSC or RSO, depending on the planned research
    • Requirements
      • Complete and submit a user enrollment form (PDF) for each individual.
      • Minors must wear a monthly body and ring dosimeter when working with or around radioactive materials.
        • Read How to Add or Delete Radiation Dosimetry Badges.
          Note: The dose to a minor is limited to 10% of the adult dose limit.
        • Read Radiation Exposure Monitoring Overview.