Requirements for Minors Performing Research

Obtain written authorization before the minor begins scheduled assignment in the lab that uses hazardous chemicals, biohazardous or infectious materials, radioactive materials or radiation-producing equipment, or where physical hazards include (but are not limited to) compressed gases, high voltage, extreme temperatures, excessive noise, or lasers. This policy applies to all minors involved in summer internships, volunteering in research projects, and participating in a scheduled assignment in a laboratory setting.

1. Request authorization by completing the Hazard Review Form for Minors Performing Research in Laboratories (Please use Chrome or IE to fill in PDF form):

• Describe project, designate a qualified adult laboratory supervisor, and obtain written authorization from the PI, supervisor, minor, and minor’s parent/guardian.
• Review the minor’s responsibilities in the lab.
• Obtain signatures of both the minor and the parent/guardian.

2. Send the completed Minors in Lab Packet to EH&S via email to minorsinlab@ucsd.edu.

3. EH&S will review the form. If approved, EH&S will return the approval letter with the original form to the PI, authorizing the minor to enter the lab. Please allow 2 weeks for EH&S to review submitted documents. If EH&S has any questions, you will be contacted for hazard clarification. 

4. Keep the approved letter and form in your departmental files for 3 years.

Note: Only minors working with hazards present in the lab are required to complete the Hazard Review Form.

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 Hazard Review Form for Minors Performing Research in Laboratories. 
  • 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 cannot be present, an alternate supervisor, formally named on the Hazard Review Form for Minors Performing Research in Laboratories, may substitute. 

• Confirm the minor receives appropriate laboratory safety training:
  • Complete a New Laboratory Worker Checklist (PDF) before the minor begins the scheduled assignment.
  • See Safety Training for Researchers.
  • Keep training documentation in the lab's files, including the New Laboratory Worker Checklist form.

• Explain hazards specific to your lab, equipment, and the materials the minor may use:
  • Show the minor how to access and understand Safety Data Sheets (SDSs).
    • See Safety Data Sheets (MSDS) Explained.
  • Explain possible routes of exposure, as appropriate (skin absorption, ingestion, inhalation, etc.) and precautionary measures to limit exposures.
  • Evaluate each potential hazard present in the work environment (e.g., compressed gases, high voltage, extreme temperatures, excessive noise, lasers, etc.) the minor may encounter and:
    • Review the potential hazards.
    • Review safe operating procedures for the equipment.
    • Review emergency procedures for the equipment.
    • Establish specific and explicit written instructions (Standard Operating Procedures) for the work the minor is allowed to perform.
  • Provide appropriate personal protective equipment (PPE) and engineering controls, and train the minor in their proper use.

Instruct the minor on emergency procedures.

• Review emergency procedures with the minor:
  • Building exits
  • Where to assemble outside in case of building evacuation
• Show the minor where emergency equipment is and how to use it:
  • UC San Diego Emergency Guide
  • Telephone and emergency phone numbers
  • First-aid kit
  • Eyewash and emergency shower
  • Fire alarm pull stations and fire extinguishers*

* Notice: In case of fire, your first responsibility is to escape unharmed and sound the alarm. Use a fire extinguisher only if you have been trained to use one and you have a clear exit path behind you.

Minors are prohibited from using the following equipment: autoclave, microtomes, cryostats, anaerobic chambers, atomic layer deposition (ALD), ultracentrifuge, and rotary evaporators. Minors may engage in observation-only activities with this lab equipment.

Vehicles and forklifts are also restricted from Minors' use.

Restrictions

Minors are not allowed to work with specific hazardous materials including:

• Controlled substances – Minors are never permitted in any setting where research involving controlled substances is being actively performed, even if they are enrolled as students. Controlled substances must remain in their locked storage areas while the minor is in the lab and cannot be accessed/used while the minor is in the area.
• Highly hazardous materials, including pyrophorics, explosives, large quantities of flammable materials (i.e., 4 liters or more), and compounds having a rat oral LD50 less than or equal to 50 mg/Kg (e.g., hydrofluoric acid, acrylonitrile, osmium tetroxide, etc.)
• International Agency for Research on Cancer (IARC) Group 1 or 2A carcinogens or Cal/OSHA-regulated carcinogens
• Additionally, the following items are commonly requested (and denied) chemical hazards listed on proposed project. Please do not include these in the scope of the project: 
  • Paraformaldehyde  
  • Formaldehyde 
  • Acrylamide  
  • Bis-Acrylamide 
  • Formalin  
  • Concentrated Ethidium Bromide 
  • Chloroform 

Training

• Make sure the minor completes required safety training before beginning work with chemicals.
  • See Safety Training for Researchers.
• Follow General Chemical Safety Guidelines.

Restrictions

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

• Minors may never work with or be present in circumstances requiring BSL-3 or BSL-4 containment.

• Minors between the ages of 14 and 15:
  • Are prohibited from handling biohazardous materials that require containment above BSL-1.
  • May enter a 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.
  • Agents approved at BSL-2 and BSL-2+ are not approved for this age group. The minor may enter 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 17:
  • Are approved for work at the BSL-2 and lower. The agents approved at BSL-2+ are not approved for this age group and the minor should not enter spaces where BSL-2+ is conducted. 
  • Are prohibited from working with biohazardous materials above BSL-2.
  • May enter a 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 decide to develop a tiered level of training, confirming competency at each level before going to the next level of difficulty or increased hazard.

Minors must be provided with appropriate medical surveillance and training, if applicable.

If work will involve human or primate blood, body fluids, or tissues, the minor and their parent or guardian must:

• Be offered the Hepatitis B vaccine at no cost, or the parent or guardian must sign a declination form.
• Hepatitis B vaccination can be obtained by contacting UC San Diego Center for Occupational Health and Environmental Medicine (COEM) to schedule an appointment for vaccination. (Note: The PI must provide a department account code for COEM to use for recharge).
  • La Jolla location: (858) 657-1600
  • Hillcrest location: (619) 471-9214

Follow UC San Diego Animal Care Program policies if working with laboratory animals.

Requirements 

• Minors must be issued the same level of protection as all laser users in the laser-controlled area.  

• Appropriate laser safety eyewear must be worn when in the laser-controlled area(s) when the laser(s) is energized. 

Restrictions 

Minors are not permitted to work with an open beam class 3B and/or class 4A laser or laser systems under any circumstances. All minors are required to be under direct supervision when in a laser-controlled area.  

Training 

Minors involved in laser project(s) must:  

• Have laser safety training given by the PI or the laboratory laser operator 

• Additional training is available by contacting the laser safety officer at ehslaser@ucsd.edu 

Restrictions

Minors are not allowed to handle radioactive materials or radiation-producing machines. PIs must apply to their campus EH&S Radiation Safety Officer (RSO) for exceptions. Exceptions must be documented in writing.

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

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. Note: The dose to a minor is limited to 10% of the adult dose limit.
  • Read How to Add or Delete Radiation Dosimetry Badges.
  • Read Radiation Exposure Monitoring Overview.

Training

Minors working with eligible radioactive materials must:

• Attend Radiation: Safety Seminar (login required)
• Get additional training if required by the Radiation Safety Committee or RSO, depending on the planned research

Restrictions

Persons under age 18 are not permitted in UC vivaria unless their participation has been reviewed and approved by the campus Institutional Animal Care and Use Committee (IACUC) and the responsible vivarium facility manager based upon criteria established by the campus.

• Contact IACUC for approval procedures and requirements.