June 30, 2020

Minors in Laboratories and Shops

INTRODUCTION

USC encourages and actively promotes creative education, hands-on workshops, and the mentoring of minors (children under 18) who attend educational events on USC campuses. To safeguard their health and well-being, the requirements of this policy apply to any minors who visit, tour, or volunteer in USC laboratories and shops that contain any of the following:

  • Radiation hazards (e.g., radioactive materials, radiation-producing machines, lasers, high-power microwave or radio wave sources)
  • Biohazards such as infectious microorganisms or potentially infectious materials
  • Hazardous chemicals (e.g., flammables, corrosives, reactive materials, toxic agents, sensitizers, and irritants)
  • Chemical-physical hazards (e.g., compressed gases, cryogens, explosives)
  • Physical hazards (e.g., extreme temperatures, glassware under vacuum, high power audible sound or ultrasound)
  • Hazardous equipment (e.g., circular saws, band saws, power tools, sharps, drill presses, lathes, and welding equipment)

Laboratories or shops that do not contain any hazards listed above (e.g., computer labs) are exempt from the requirements below.

Note that minors related to university employees are not allowed to accompany employees into laboratories and shops unless they are enrolled in a formal university program.

CALIFORNIA LABOR LAWS AND UNIVERSITY POLICIES

Principal Investigators, supervising faculty, managers, departments, and schools should familiarize themselves with the following references to ensure strict compliance with state law and university policies.

Failure to comply with California labor laws, university policies, or these guidelines is subject to sanctions as per Section VIII of the Protecting Minors Policy.

AGE RESTRICTIONS

  1. No one under the age of 14 is permitted in university laboratories, shops, or other hazardous areas unless they are part of an organized, university-approved tour, an organized university program, or a department-sponsored program. Organized tours must include direct supervision, at all times, by university faculty and/or staff knowledgeable of all inherent dangers and risks.
  2. Minors between the ages of 14 and 17 may be permitted to pass through potentially hazardous work areas only if they are protected from the potential hazards and risks as deemed appropriate.
  3. Minors between the ages of 14 and 17 may be permitted to participate in a laboratory or shop with potentially hazardous materials only if they have satisfied all training requirements outlined below, and the necessary consent documents are completed and signed as outlined below.
  4. Minors of any age are NOT eligible to become authorized users of DEA controlled substances. Additionally, all controlled substances MUST be locked in approved storage locations for the duration of the tour.
  5. Minors of any age are NOT permitted in USC vivaria UNLESS approval is granted by the Institutional Animal Care and Use Committee, the Director of the Department of Animal Resources (or designee), and the responsible vivarium facility manager.

ACTIVITIES

Tours

Organized tours must include direct supervision at all times by university faculty and/or staff knowledgeable of all inherent dangers and risks.

Lab tours

  • No hazardous activity will be performed while minors are touring the facilities. Hazardous activity includes use of toxic/radioactive and/or highly reactive materials, lasers, or radiation-producing devices. Contact ehs@usc.edu if there are further questions regarding what constitutes hazardous activity in labs/shops and/or if guidance is needed.
  • No minor will handle hazardous materials (chemical, radioactive) or biohazardous agents or engage in activities involving such materials.
  • Minors will wear appropriate PPE (e.g., eye protection) as determined by the Principal Investigator, supervising faculty, or lab manager.
  • High diversion risk DEA controlled substances (e.g., Schedule 1 substances or undiluted ketamine) must be locked in the approved secure storage location for the duration of the tour. Other controlled substances must either be locked in the approved secure storage location or be under the direct control and observation of an authorized user during the duration of the tour.

Shop tours

  • No hazardous activity will be performed while minors are touring the facilities. Hazardous activity includes use of arc or oxy/acetylene welding, plasma cutters, hazardous materials, high decibel noise from shop equipment, or dust/particulates from sanding.
  • No minor will engage in hazardous shop activities including those that involve hazardous chemicals.
  • Minors will wear appropriate PPE (e.g., eye protection) as determined by supervising faculty or shop manager.

Educational activities in areas with potentially hazardous materials/equipment

Minors between the ages of 14 and 17 may participate in educational activities at a USC lab or shop as follows:

  • Minors must be sponsored by a faculty member or Principal Investigator.
  • Minors participating in approved host school or department-sponsored educational programs may engage in low-risk activities under direct supervision at all times by a faculty and/or staff member:
    • Minors may handle benign chemicals under well controlled, low-risk conditions at the discretion of the Principal Investigator. The minor may handle benign biological materials or radioactive materials below exempt quantities at the discretion of the Principal Investigator.
    • Minors may NOT handle: radioactive materials over exempt quantities, highly hazardous chemicals (pyrophoric, explosive, toxic/highly toxic), materials at Biosafety Level 2 or higher (including rDNA, human blood, tissue, cell cultures, or pathogens), controlled substances of any quantity, or research animals.
    • Minors may engage in low-risk shop activities (e.g., use of hand tools and power hand tools such as a cordless drill) as determined by the shop manager only under close supervision. The shop manager may also allow minors very limited use of table saws, drill presses, lathes, and other shop machines while under close supervision and with machine guards in place.
  • Minors must wear appropriate personal protective equipment (PPE) in accordance with the USC PPE Standard. The Principal Investigator, supervising faculty member, or lab/shop manager will evaluate and determine the appropriate level of protection.
  • Minors are NOT permitted to conduct activities or be present in areas requiring respiratory protection.
  • Minors are NOT permitted to be present in areas where personal radiation dosimetry is required.
  • Minors are NOT eligible for individual card or key access to labs, shops, or internal or external doors of USC buildings housing labs or shops.

SUPERVISION REQUIREMENTS

The Principal Investigator, supervising faculty member, or lab/shop manager is responsible for:

  • the health and safety of minors working in their laboratories or shops, and
  • adherence to state regulations and university policies, including the provision for and enforcement of correct use of engineering controls, work practices, and personal protective equipment.

The Principal Investigator/shop manager may delegate daily supervision of minors to trained and knowledgeable lab or shop employees. However, the Principal Investigator/shop manager retains primary responsibility. Minors may only work in laboratories or shops under direct supervision by the Principal Investigator/shop manager or designated lab or shop employees. Minors are NOT permitted to be alone in the lab or shop and must be physically accompanied at all times while entering, leaving, or in the lab or shop.

The Principal Investigator/shop manager must ensure designated supervisory personnel (which may include graduate students, postdocs, or other staff) are suitably trained, experienced, and apprised of their role and responsibilities.

TRAINING REQUIREMENTS

Tours

Supervising faculty or staff must provide a basic safety orientation to tour participants before the tour begins. The orientation must include discussion of specific site hazards.

Research in areas with potentially hazardous materials/equipment

Minors working in laboratories or shops are required to complete all appropriate safety training before beginning work. The Principal Investigator/shop manager must ensure that appropriate safety training is provided, and that records of minors’ safety trainings are electronically or manually filed. Information and instructions for training registration are available at the Environmental Health and Safety webpage.

Lab

  • General Lab Safety Training. USC staff, postdocs, students, and volunteers (including minors) are required to attend and pass this training before being permitted to work in a research lab. Attendees will receive full credit with attendance and completion of assignments. (Follow instructions for registration at http://ehs.usc.edu/training/registration/ under “Visiting Scholars, Volunteers, and High School Students.”)
  • Bloodborne Pathogen Training. This training is for anyone who will work with or around human (or non-human primate) materials, such as blood tissue, other body fluids or cell lines, and for those who work in a clinical setting around patients.
  • Principles of Biosafety. This course covers safe practices for handling and containment of biological materials including human blood, human pathogens, recombinant DNA, and biological toxins.
  • Radiation Safety. Anyone working with, or with the potential to be exposed to radiation or radioactive materials must attend.
  • Lab-specific training (including safety refresher training). Must be provided to minors and research staff by the Principal Investigator or designee.
  • PPE for the Laboratory; video with quiz.

Shop

  • Basic Shop Safety
  • PPE for Shops; video with quiz

CONSENT FORMS

Consent forms outlined below must be completed and signed BEFORE the minor may begin work in or tour the lab or shop.

  • The faculty sponsor will complete the USC Lab or Shop Consent for High School Student Participation form that describes the work the high school student will undertake along with a list of appropriate PPE.
    • This form will be signed by faculty sponsor, Principal Investigator, department chair, and the parent/guardian of the student. Additionally,
  • The parent/guardian will complete and sign the following forms:
    • USC Parent/Legal Guardian Consent for Minor Working in Potentially Hazardous Work Areas – this form includes a “Release for Emergency Medical Treatment” statement.
    • Physician’s Medical Clearance for Minor Working in Areas with Animals – to be completed by minor’s personal physician and parent/guardian.

The forms will be kept on file by the host school/department and Principal Investigator. A copy of the signed forms must be readily available in case the student is injured or becomes ill and is transported to a medical facility.

The minor’s parent or legal guardian is responsible for the cost of any medical treatment provided as the result of a lab-related or shop-related injury or illness. If the minor is employed by USC as a student worker, then medical treatment is covered under USC workers’ compensation provisions.

  • The minor will complete and sign the USC Minor’s Agreement for Working in Potentially Hazardous Work Areas form. The form will be kept on file by the host school/department and PI.

Retention of consent forms is subject to the university’s Record Management policy.

EMERGENCY NOTIFICATION AND INCIDENT REPORTING

In the event of an emergency involving a minor, follow steps outlined on the Emergency Notification and Incident Reporting webpage and notify parent/guardian.

For non-emergency injuries and/or illnesses, consult the Non-Emergency Injury and Illness Reporting Fact Sheet.

Responsible office

Environmental Health and Safety

https://ehs.usc.edu/
ehs@usc.edu
(213) 740-2325