Working Alone Policy

On May 22, 2012 MIT Academic Council adopted the following Working Alone Policy and Guiding Principles (PDF). This policy is linked from Policies & Procedures Section 9.14.2 and Sections 3.1 and 5.4.1 of the Employment Policy Manual.  DLC-EHS Staff and EHS Office will assist in the implementation of the policy. For more information contact the EHS Office at environment@mit.edu.

As a practice, working alone with hazardous materials, equipment or otherwise working under conditions that may create the risk of serious injury (hereafter referred to as hazardous conditions) should be avoided.

Anyone at MIT (faculty, staff, students, and visitors) who works with (or intends to work with) potentially hazardous conditions (in any location, i.e. laboratories, shops, field work) that may result in immediate injury or serious harm must discuss this activity with their Principal Investigator (PI) or supervisor prior to conducting the work alone and determine that the risk of working alone is controllable under the specific conditions established by the PI or supervisor for the work. If the PI or supervisor determines that the risk cannot be minimized to a controllable level, then the individual should perform the work only when others are present or a suitable alarm device is available that will summon help immediately.

Furthermore, undergraduates shall not work alone with hazardous materials, equipment, or operations that can result in immediate injury or death without prior written approval from the immediate PI or supervisor. Written approval should only be granted after the risk assessment is performed and reviewed by the PI or supervisor with the individual.

This policy states the minimum requirements for working alone across the Institute and supersedes any less restrictive policy or procedure. Specific Working Alone policies from Institute Committees or individual DLCs or individual PIs or supervisors that are more restrictive shall take precedence.

Guiding Principles in Support of MIT’s Working Alone Policy

Scope

While it is recognized that nearly all activities in a laboratory could result in serious injury (e.g., cuts from broken glass or hitting one’s head in a fall) the intent of this policy is to have the PI or supervisor and the individuals involved make a careful assessment of the activities involved that may create a potentially hazardous condition.

This policy would not apply to areas outside laboratories such as offices, conference rooms, tea rooms, break rooms, or classrooms, where hazardous materials, equipment, or operations would not be expected to be present. It is intended to mitigate those incidents or accidents where there is an immediate need for assistance from one or more individuals to provide help and/or call for assistance (e.g., emergency responders).

Working alone applies to anytime night or day. Working alone means when no one else is in direct line of sight or within sound of the person. When possible arranging your work to have a lab partner in the same location is preferable.  Under some conditions alternative means of communicating may substitute.

The available options listed below will need to be evaluated on a case-by-case basis with advice from the EHS Coordinator and the EHS Office.

• Streaming a video chat through a remote conferencing service while someone is doing higher risk lab work.
• Using the video chat features available on your cell phone over WiFi.
• Scheduling calls and/or texts (Verify that that your cell phone has reliable reception before deciding if it would be a viable option. This varies by cell phone company and by building. If cell phone reception is not reliable consider using an online messaging platform)

For each option, it is important to schedule a primary person and back up person for each working alone time period. Note that the Campus Safety Working Group is not presently approving requests for wearable devices. This group also reviews and renders decisions and recommendations for video surveillance systems.

Hazardous Conditions Assessment

Hazardous conditions that can result in immediate injury or death must be defined by the PI or supervisor with assistance from the EHS Coordinator or the EHS Office on a case-by-case basis. This may include work with animals such as primates. Once this review is done it does not need to be repeated for subsequent similar activities. A system will be established and maintained by the EHS Office to compile individual conditions, which a PI or supervisor can refer to for guidance. The EHS Office will serve to provide consistency across the campus.

Some form of formal or informal risk assessment should have already been completed prior to initiation of the potentially hazardous work as required by a DLC’s Chemical Hygiene Plan, Hazard Communication Plan, Laser Safety Plan, Job Safety Analysis, Standard Operating Procedure, or other relevant DLC plans, policies or procedures.

Undergraduate’s guidance

For undergraduates, written approval is needed each time the hazardous material, equipment or operation and/or location change. The review need only be done and agreed to once for generic operations where the risks will not change provided the conditions agreed to are followed. The approval is based on the PI’s or supervisor’s assessment that the undergraduate has adequate skills and responsibility to perform the work under the specified conditions.

An example form that can be used to document the decisions is listed below.

Undergraduate Example Form

Risk Assessments

Factors to consider when making the risk assessment are: toxicity, reactivity, corrosivity, explosivity of the material; quantity; control procedures (PPE, fume hoods, shields, etc.); availability of emergency equipment such as eyewashes and emergency showers; potential energy of the equipment or material; complexity of machinery or equipment; difficulty of manipulations; training, experience and demonstrated good judgment of the individual; level of uncertainty about any of the above. All these lead to determining the level of control that is needed and can be maintained to reduce the risk.

Some examples of controls that can be used to eliminate or reduce risk to an acceptable level are:

1. Perform the activity in a fume hood or glove box or other enclosure
2. Limiting the quantity of materials
3. Wearing appropriate PPE

Examples of materials or activities where working alone is discouraged:

1. Work with pyrophoric materials
2. Work with highly reactive materials
3. Work involving entry into a confined space
4. Workaround high voltage
5. Certain machine shop activities

A partial list of Current policies that are stricter and override the Institute policy:

1. Committee on Animal Care (CAC) and Division of Comparative Medicine (DCM)
2. Radiation Protection Committee (RPC): No undergraduates can work alone in the gamma irradiation facilities. All other work with radioactive material is permitted following the Institute’s Working Alone policy and approval of the Radiation Protection Committee. The RPC may impose working alone restrictions in the conditions of approval for radioactive materials use authorizations.
3. Committee on the Assessment of Biohazards/ Embryonic Stem Cell Research Oversight (CAB/ESCRO) (certificate login required)
4. Plasma Science and Fusion Center (PFSC), see General Laboratory Safety Rules and Policies
5. Lincoln Laboratory (LL): Contact LL EHS Office for information about LL’s policy, safety@ll.mit.edu or 781-981-2380
6. MIT Chemical Hygiene Plan (CHP)