General Laboratory Safety
Requirements for Minors Performing Research
Principal investigators - follow these steps to get University of Michigan authorization and parental permission for a minor to participate in independent research activities*, and to meet supervision, training, and hazardous materials requirements and restrictions. Read OSEH Guideline on Laboratory Visitors & Volunteers, which gives details on age restrictions and the principal investigator's responsibilities.
* The scope of this policy does not include university-sanctioned programs for the introduction of high-school students to the sciences, where minors are closely and continuously monitored by instructional staff. Examples include summer science camps and related outreach programs held during the academic year. Such programs do not constitute independent research activity.
1. Get authorization before the minor enters the lab
Request authorization by submitting the 2 forms below:
- DISCLOSURE - Form 1 - Print out and complete the 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.
- PERMISSION - Form 2 - Print out and complete the 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 departmental files for 2 years after the minor turns 18 years old.
Send copies of both the completed Project Checklist form and the Waiver to:
- UM-OSEH – Biosafety Program - CSSB Building, Campus Box 1010 (Fax 3-1185)
Keep the approved original forms in your departmental files.
- In addition, to complying with the OSEH requirements of minors performing research, principal investigators are responsible for understanding and complying with University policies on volunteers and employment. Please review the following policies:
- Employment of Minors: SPG 201.20
- A Temporary Employment Form 3700 must be completed; as well as the work permit process.
- Appointment of Relatives: SPG 201.23
Temporary Employment: SPG 201.57
University of Michigan Volunteer Guidelines
- Volunteer Special Placement Procedure - UM Medical System has special requirements for minor volunteers who seek to be placed in specific research laboratories.
- If you have any questions regarding your ability to have a minor volunteer or work in your research lab, please consult with your department Human Resources Consultant.
2. Ensure supervision requirements are observed
Minors are prohibited from working alone in U-M laboratories.
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.
3. Instruct the minor on emergency procedures
Review the University of Michigan Emergency Procedures Flip Chart with the minor. Show the minor the following emergency equipment and locations:
- Telephone and emergency phone number (911 for UM-DPS)
- First-aid kit
- Eye wash and emergency shower
- Fire alarm pull stations and fire extinguishers
- Building exits – means of egress signs posted
- Where to assemble outside in case of building evacuation
4. Provide general laboratory safety training
Make sure the minor receives appropriate laboratory safety training:
- Begin by enrolling the minor in OSEH’s "Comprehensive Laboratory Safety Training" course, given twice monthly at the OSEH location at CSSB Building on South Campus.
- Since the minor may not have a UM-ID, online enrollment may be difficult. Phone the OSEH Training Coordinator at 7-2231 to facilitate this enrollment process.
- Receive a copy of the certificate of training given by OSEH to the minor to document the training.
- Keep all safety training documentation in the laboratory’s personnel training 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. See OSEH Website MSDS access.
- Explain possible routes of exposure, as appropriate:
- Skin absorption
- Provide personal protective equipment (PPE), explain safe use of chemical fume hoods & biological safety cabinets, and train the minor in their proper use.
5. Observe hazardous materials restrictions and safety training requirements
Follow these restrictions and safety training requirements:
- Chemical safety:
- Minors are not allowed to work with:
- Ensure the minor is familiar with the General Chemical Safety Guidelines described in the Chemical Hygiene Plan for the laboratory
- Ensure that all aspects of required safety training have been covered with the minor for your specific laboratory operations by filling out the new research worker checklist.
- Biological safety:
- 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 (Risk Group 1 agents using BSL-1 practices and precautions).
- 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 biosafety level 2 (Risk Group 2 agents using BSL-2 practices and precautions).
- May enter and work at BSL-2 with appropriate training and medical surveillance (if applicable).
- Minors permitted to work at BSL-2 must receive job-specific training from the responsible PI.
- Minors must be provided with appropriate medical surveillance and training, if applicable.
- If work will involve human blood, body fluids, or tissues, the laboratory’s Exposure Control Plan requires that the minor and their parent or guardian:
- Be offered the Hepatitis B immunization at no cost, or the parent or guardian must sign a declination form.
- Radiation safety:
- Restrictions: Minors are generally prohibited from handling radioactive materials.
- PIs may apply for an exception to allow a minor to work under the direct supervision of an Authorized User approved by the Radiation Policy Committee with up to 1 millicurie of a radionuclide per experiment.
- Apply to the Radiation Safety Officer (RSO) for exceptions.
- Animal Use:
- Restrictions: Minors are generally prohibited from handling research animals.
- PIs may apply for an exception to allow a minor to work with lab animals under the direct supervision of an Authorized User approved by the University Committee for the Use and Care of Animals (UCUCA).
- Apply to the ULAM Director for exceptions.