Minors in Laboratories, Hazardous Areas and Animal Facilities

Type of Policy: 
Administrative
Effective Date: 
December 2016
Last Revised: 
December 2016
Review Date: 
December 2019
Policy Owner: 
Environmental Health & Safety
Contact Name: 
Nazia Zakir
Contact Title: 
AVP of EHS
Contact Email: 
nazia.zakir@ehs.gatech.edu
Reason for Policy: 
This policy establishes the requirements used by the Office of Environmental Health and Safety (EHS) at the Georgia Institute of Technology (Georgia Tech) to authorize persons under 18 to be present in a laboratory, hazardous area or animal facility at Georgia Tech. Georgia Tech’s support of its community involves reaching out to students for educational and research purposes. Because of their biological, social, and maturational characteristics, minors may have unique and substantial risks for work-related injuries and illnesses which must be assessed and addressed prior to permitting a minor to enter laboratory areas or other areas where potentially hazardous materials or conditions may be present. The presence of minors must also comply with all Federal, State, and Board of Regents regulations and Georgia Tech’s Institutional Policies and Procedures.
Policy Statement: 

Minors are prohibited from entering laboratories, hazardous areas (e.g. machine shop) or animal facilities where potentially hazardous materials or conditions may be present, except when the Minor has been pre-authorized in writing by a hiring or volunteer manager and approved by the AVP of EHS.

If a Minor is permitted in a laboratory, hazardous area or animal facility, the following requirements must be met:

  1. Their direct supervisor or assigned mentor shall be a Georgia Tech employee who shall maintain a constant line of sight supervision of the Minor.
  2. No Minor under the age of 16 may be employed in a laboratory or hazardous area.
  3. Minors shall not be in any setting involving exposure to explosive materials.
  4. A Minor shall not be in any setting involving exposure to ionizing radiation. Minors are not permitted to operate any X-ray producing equipment. Operation of machines producing by-product X-rays, such as electron microscopes, may be conditionally allowed.
  5. Minors are not permitted to handle the following highly hazardous materials – pyrophoric, 4 liters or more of flammable liquids, or compounds having a rat oral LD50 less than or equal to 50mg/Kg (e.g. hydrofluoric acid, acrylonitrile, osmium tetroxide, etc.) or as directed by EHS.
  6. A Minor may not participate in animal research or animal handling without approval from the Institutional Animal Care and Use Committee (IACUC) in an approved protocol.
  7. Minors are not permitted to work with certain biological agents and toxins as defined by the Federal Select Agents Program.
  8. Minors are prohibited from participating in the following research:
    1. Research that requires the Minor to assign ownership interest in any resulting intellectual property to the Georgia Tech Research Corporation or other third party.
    2. Research that fits the definition of Dual Use Research of Concern (DURC).
    3. Research that requires confidentiality agreements or that may include agreements or funding which include restrictions on participants.
    4. Research with public disclosures of prior art (due to the potential loss of patents).
  9. Minors shall not be permitted to drive an Institute motor vehicle, including, but not limited to, a low speed vehicle, golf cart or maintenance utility vehicle.
Scope: 
This policy applies Minors (persons under 18 years of age) who enter laboratories or other hazardous areas. This policy excludes and does not apply to Minors who are enrolled at Georgia Tech or to Minors participating in an adult escorted, scheduled demonstration or tour. These excluded Minors are expected to follow safety instructions and safety rules but do not require compliance with this Policy.
Procedures: 
  1. The parent/legal guardian of the Minor will complete the “Consent for Minor’s Presence in Laboratory” and “Parental Request to Participate Release and Waiver Agreement” and returns them to the hiring or volunteer manager prior to the Minor beginning work or volunteer activities. The hiring or volunteer manager will submit copies to EHS.
  2. The hiring or volunteer manager will contact EHS and complete an “Application for Authorization of a Minor (16 or 17 years of age) to Work or Volunteer in a Laboratory or other Hazardous Area.” This application prompts information pertaining to the potential hazards in the area the Minor will be working or volunteering. This application must also be signed by the Department Chair.
  3. As part of its review process, EHS will review the proposed activities, materials and equipment in the Application in order to determine if the preventative measures listed are satisfactory; confirm any additional approval from the IACUC, Institutional Biosafety Committee (IBC), Radiation Safety Committee (RSC), or other Institute committee or group, if needed; and verify that the Consent and Parental Request Form (mentioned above) are complete.  Once the review is completed, then Authorization will be granted.   Authorization must occur prior to the Minor’s access to the laboratory, hazardous area or animal facility. If the project changes or the scope of duties/research changes or additional are identified, additional information will need to be submitted.   The Minor’s access may be suspended during review of the new information.
  4. EHS will notify the hiring or volunteer manager when a Minor has been authorized to work in a laboratory, hazardous area or animal facility and will provide copies of the executed documents.
  5. A hiring or volunteer manager who fails to complete these requirements prior to the Minor beginning his or her research/work/volunteer activities may be subject to disciplinary action.
  6. The Minor must take any required training in biosafety, radiological safety, lab safety, right to know, or as determined by the AVP of EHS, as well as any occupational health or vaccination requirements prior to beginning work in the laboratory. Training information is found at https://ehs.gatech.edu/training.
  7. The Principal Investigator (PI) and mentor must be in compliance with the Minors on Campus Policy including but not limited to training or background checks that may be required.  The PI and mentor must also comply with the Mandatory Reporting of Child Abuse Policy.
Responsibilities: 

Principal Investigator
The PI is responsible for only allowing Minors in their laboratories, hazardous areas or animal facilities that have fulfilled the requirements of this Policy, for maintaining a constant line of sight supervision of the Minor at all times while in the lab; making sure that the Minor is working in the lab according to safety policy and prohibiting them from continuing work if they cannot follow safety policy and plans; reporting any accidents or incidents involving the Minor and for keeping the laboratory in compliance with EHS Policies and Procedures.  In the event that the PI cannot provide line of sight supervision, they must assign a mentor for the Minor, which is documented on the “Application for authorization of a minor (16 or 17 years of age) to work or volunteer in a laboratory or other Hazardous Area)”.  Any PI supervising Minors must follow the Georgia Tech Child Abuse Prevention Policy and the “General Procedures for Working with Minors”, and ensure that the space will be compliant with this Procedure and the documentation for the screening and training are maintained per policy. 

Mentor
A mentor is an employee of the Institute and must be assigned by the PI if the PI cannot provide direct supervision. It is expected that the mentor will have a constant line of sight of the Minor while in the laboratory, hazardous environment or animal facility. The mentor is responsible for making sure the Minor has fulfilled the requirements of this Policy; making sure that the Minor is working in the lab according to safety policy and prohibiting them from continuing work if they cannot follow safety policy; reporting any accidents or incidents involving the Minor; and maintaining a constant line of sight supervision of the Minor at all times while in the lab. Any mentor supervising Minors must follow the Georgia Tech Child Abuse Prevention Policy and the “General Procedures for Working with Minors” and ensure that the space will be compliant with this Procedure and the documentation for the screening and training are maintained per policy. The mentor must be an adult as defined by in the Child Abuse Prevention policy. 

Hiring or Volunteer Manager
The hiring or volunteer manager is responsible for making sure that the documents required in the Procedure in this Policy have been completed for the Minor.

Environmental Health & Safety
EHS is responsible for reviewing and determining approval for submitted “Applications for Authorization of a Minor…” in a timely manner and notifying the manager when authorization has been granted.  Review of the form may include obtaining additional information, conducting an inspection of the space, and providing the required safety training and additional safety measures. 

Enforcement: 

To report suspected instances of noncompliance with this policy, please contact Environmental Health and Safety or visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History: 
Revision Date Author Description
12/16/2016 EHS New Policy
Map of Georgia Tech

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