Applies to: All University of Southern California (“USC”) schools and departments regarding any minor who visits, tours, or volunteers in USC laboratories or shops.
1. Policy
Issued: June 30, 2020
Last Revised: June 30, 2020
Last Reviewed: November 29, 2022
2. Policy Purpose
To set forth the responsibilities and requirements for USC departments, schools, and personnel to help protect the safety of minors while they are attending USC’s laboratories, hands-on shops, and other education events.
3. Scope and Application
This policy applies to all USC schools, departments, and personnel located on University owned or leased property, and/or if engaged in University business or activities in off-site locations. The requirements of this policy apply when minors 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, and high-power microwave or radio wave sources)
- Biohazards (e.g., 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 this policy.
Additionally, minors who are related to and/or guests of USC employees, are not permitted to accompany employees into laboratories or shops unless they are enrolled in a formal university program that allows for them to do so.
4. Definitions
| Term | Definition |
| Minor | People under the age of 18 |
| Laboratory | Place where one conducts scientific experiments, processes, or other types of research. |
| Shop | Place in which one constructs, repairs or makes things, which may involve the use of machine tools such as lathes, milling machines and various hand tools. See https://ehs.usc.edu/occhealth/shop-safety/ for further details. |
5. Policy Details
USC encourages and actively promotes creative education, hands-on shops, and the mentoring of minors who attend USC educational events. This policy and USC’s related safety practices and programs are intended to protect the safety, health, and well-being of the minors while also complying with local, state, and federal regulatory standards.
CALIFORNIA LABOR LAWS AND UNIVERSITY POLICIES
Workplace, shop, and laboratory supervisors and managers (e.g., principal investigators, supervising faculty, managers, departments, and schools need to familiarize themselves with the following to ensure compliance with state law and related USC policies.
- State of California Child Labor Laws
- USC Protecting Minors Policy
- USC Office of Equity and Diversity – Protecting Minors in the Workplace Standards
Failure to comply with California labor laws or university policies is subject to disciplinary actions and sanctions in accordance with university policies, and as specifically indicated in the USC Protecting Minors Policy.
RESTRICTIONS BY AGE
- Minors under the age of 14 are not 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.
- Minors between the ages of 14 and 17 may be permitted to pass through potentially hazardous work areas only if they are adequately protected from the potential hazards and risks.
- 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, and the required consent documents are completed and signed as outlined in this policy (please see further below for detailed information).
- Minors of any age are NOT eligible to become authorized users of controlled substances as defined and regulated by the U.S. Drug Enforcement Administration (DEA). Additionally, all controlled substances must be locked in approved storage locations for the duration of an organized tour with minors in attendance.
- Minors of any age are NOT permitted in USC vivaria unless approval is granted by the USC 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 of laboratories and shops with minors in attendance must include direct supervision at all times by university faculty and/or staff knowledgeable of all inherent dangers and risks.
Laboratory Tour Requirements
- No hazardous activity may 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. Please contact USC Environmental Health & Safety (EH&S) with questions regarding what constitutes a hazardous activity and/or if further 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 laboratory manager.
- High diversion risk controlled substances (e.g., U.S. DEA Schedule 1 substances or undiluted ketamine) must be locked in an approved secure storage location for the duration of the tour. Other controlled substances must either be locked in an approved secure storage location or be under the direct control and observation of an authorized user for the duration of the tour.
Shops Tour Requirements
- 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
Minors between the ages of 14 and 17 may participate in educational activities at a USC laboratory or shop that has potentially hazardous materials or equipment under the following requirements:
- Minors must be sponsored by a faculty member or Principal Investigator.
- Minors participating in approved 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 and only under close supervision. The shop manager may also allow minors 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 Standards. 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 laboratories, shops, or internal or external doors of USC buildings housing laboratories or shops.
TRAINING REQUIREMENTS
Tours
Supervising faculty or staff must provide basic safety orientation to minors before entering laboratories or shops with potentially hazardous materials and/or equipment, and is to include discussion of specific site hazards.
Minors Working in Laboratories and Shops
Minors working in laboratories and shops with potentially hazardous materials or equipment are required to complete all appropriate safety training before beginning work. The Principal Investigator or 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 to register for safety trainings are available via the USC Environmental Health and Safety (EH&S) website, and please contact EH&S with questions.
Laboratory Trainings
- General Lab Safety Training: USC employees, postdocs, students, and volunteers (including minors) are required to attend and pass this training before being permitted to work in a research laboratory. (See registration instructions at http://ehs.usc.edu/training/registration/ under “Visiting Scholars, Volunteers, and High School Students.”)
- Bloodborne Pathogen Training: required for those 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: covers safe practices for handling and containment of biological materials including human blood, human pathogens, recombinant DNA, and biological toxins.
- Radiation Safety: required for those working with, or with the potential to be exposed to radiation or radioactive materials.
- Lab-specific training (including safety refresher trainings): must be provided to research staff and volunteers (including minors) by the Principal Investigator or designee.
- PPE for the Laboratory
Work Shop Trainings
- Basic Shop Safety
- PPE for Shops
PARENTAL / LEGAL GUARDIAN CONSENT & MEDICAL CLEARANCE
Formal parental/legal guardian consent is required for all minors participating in laboratory experiments at USC and/or who will be working in areas where hazardous chemical or other substances may be present. A specific consent form must be signed in advance of a minor participating in any such activities. Additionally, physician medical clearance is required for all minors working in areas with animals; this form is to be completed by both a physician and parent/legal guardian (please see “Forms” section below).
Completed 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/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 program.
ENFORCEMENT
Those who fail to comply with the terms of this policy will be subject to appropriate disciplinary action, including termination or dismissal for cause in accordance with university policies.
6. Procedures
Standard Operating Procedures for Laboratory Safety When Using Hazardous Materials:
https://ehs.usc.edu/research/lab/sop/
EH&S Safety Training & Registration:
https://ehs.usc.edu/training/registration/
7. Forms
Parental/Legal Guardian Consent for Minors Working in Potential Hazardous Areas: https://cpb-us-e1.wpmucdn.com/sites.usc.edu/dist/0/713/files/2016/12/Parent-Consent-Form.pdf
Physician’s Medical Clearance for Minors Working in Areas with Animals: https://redcap.med.usc.edu/surveys/?s=HN4H3HNK9K
Laboratory Hazard Assessment Tool (LHAT): http://tiny.cc/usc-lhat
Shop and Safety Risk Assessment Form: http://tiny.cc/usc-ssra-form
8. Responsibilities
| POSITION or OFFICE | RESPONSIBILITIES |
| USC Office of Environmental Health & Safety (EH&S) | Ensures institutional compliance with applicable policies, statutes, and regulations (including minors in laboratories or shops)Develops safety programs and monitors their effectiveness; and provides health and safety services, training, and support to university schools, departments, and administrative units. This includes creating programs, trainings, and protocols for the safe use of hazardous radiological, biological, chemical substances, and lasers in research and other learning environments.Facilitates regular, periodic inspections to identify, evaluate, and correct workplace hazards and unsafe work practices. EH&S has the authority and responsibility to curtail or shut down any university activity that constitutes a clear health and safety danger to the USC community. Develops and recommends university-wide health and safety policies for senior leadership review and approval. |
| Laboratory and Workplace Supervisors & Managers, e.g., Principle Investigators, Laboratory Instructors, Laboratory/Shop Manager, etc.) | Responsible for taking appropriate actions to help ensure the health and safety of minors working in their laboratories or shopsMust adhere to State of California regulations and university policies, including the provision for and enforcement of correct use of engineering controls, work practices, and personal protective equipment.Responsible for the supervision of minors within their laboratories or shops. May delegate daily supervision of minors to trained and knowledgeable laboratory or shop employees. 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. Note: minors may only work in laboratories or shops under direct supervision by the Principal Investigator/shop manager or designated laboratory or shop employees. Minors are NOT permitted to be alone in the laboratory or shop and must be physically accompanied at all times while entering, leaving, and while inside laboratory or shop areas. |
9. Related Information
USC Environmental Health & Safety (EH&S): https://ehs.usc.edu/about/
USC Shop Safety Program: https://ehs.usc.edu/occhealth/shop-safety/
USC Protecting Minors Policy: https://policy.usc.edu/protecting-minors/
USC Office of Equity and Diversity – Protecting Minors in the Workplace: https://protectingminors.usc.edu/about/
State of California Child Labor Laws: https://www.dir.ca.gov/dlse/dlse-cl.htm
USC Institutional Animal Care and Use Committee: https://iacuc.usc.edu/
U.S. Drug Enforcement Administration – Drug Scheduling: https://www.dea.gov/drug-information/drug-scheduling
USC Personal Protective Equipment (PPE) Standards: https://ehs.usc.edu/research/lab/manage/ppe/
10. Contacts
Please direct any questions regarding this policy to:
| OFFICE | PHONE | |
| Environmental Health & Safety | (323) 442-2200 | ehs@usc.edu |