Hire/ Host A High School Or Middle School Student (Minor)
- For the Principal Investigator, Supervisor, or EHS Rep
- Instructions for Administrative Officer/ HR Administrator
- Instructions For Parents And/Or Legal Guardian
- Instructions for EHS Coordinators and Lead Contacts (certificate log in required)
The guidelines for hiring or hosting individual minors are at Protection of Minors.
The guidelines for Programs are at Protection of Minors.
The Office of General Counsel, Human Resources, and EHS collaborated to develop these guidelines, which will assist DLCs in determining how to manage the hiring or hosting of minors. MIT encourages the DLCs to provide educational programming to minors in a safe, professional and responsible manner.
Prior to hiring or agreeing to host an intern or volunteer, the primary supervisor should verify whether there are any specific approval processes required by your DLC.
The EHS Office is available to review any type of activity involving minors, but our primary focus is minors working in labs, shops and other areas that have EHS-related hazards.
It is Institute policy to maintain certain personnel and safety practices concerning the employment of Minors. The Commonwealth of Massachusetts and the U.S. federal government place many restrictions on the type of work that may be performed by Minors and the conditions under which they work.
“MIT prohibits the employment or internships of any minors under age 16, whether paid or unpaid. Persons under 18 years of age must present certification that they are legally eligible to work. This Employment Permit is obtained through the minor’s school system. The Employment Permit must be provided to the responsible person before the minor starts work.”
This guidance and the processes for minors are intended to foster a safe environment and prevent exposure to hazardous materials, lab-acquired infections, injuries, etc.
- Principal investigators (PIs), program sponsors, and supervisors are responsible for the safety of the minors whom they hire or host, just as they are responsible for the safety of their employees and students.
- A faculty member, PI, supervisor, or a higher-level administrator shall be responsible for each program and shall designate someone to assume an EHS oversight role. The space owners share this responsibility for the programs that are conducted in their areas.
- An MIT undergraduate student cannot be solely responsible for a program and cannot be a supervisor.
WHO CAN SERVE AS A SUPERVISOR?
- Faculty, postdoctoral associates, researchers, graduate students and/or other appropriate employees of MIT may serve as supervisors.
- Non-MIT employees may not serve as supervisors. (e.g., postdoctoral fellows, visiting students/scholars, independent contractors, staff from temporary agencies like MITemps)
- Undergraduate students may not serve as supervisors.
- The AO or their designee can check a potential supervisor’s status, if necessary, and then the person could go through the background check.
SUPERVISION AND NOT WORKING ALONE
- Supervision is necessary for all minors. Minors should not under any circumstances work alone in a laboratory, shop, or other work area with identified environmental, health, and safety hazards, even if they are only using the computer.
- The primary supervisor and/or the alternate must closely supervise the minor, i.e., work with or near him/her in the lab/ shop.
- Minors should not be given keys or key card access to laboratories, shops, and other areas with identified EHS hazards. Either of these methods would potentially allow minors to work alone in an area with hazards.
- Working alone exception for undergraduates and UROPs does not apply to minors. There are no situations where it is appropriate for a minor to work alone.
HAZARD ASSESSMENT AND TRAINING
- A documented hazard assessment of the minor’s work and work area must be conducted to determine what EHS training is needed. The EHS Coordinator and/or EHS Office can assist with this assessment.
- PIs, directors, and supervisors shall ensure that minors whom they hire or host have completed all applicable EHS training before the minors start working with any hazards.
- The PIs, directors, staff, and students who supervise/mentor/interact with minors shall complete all applicable training (EHS, legal, operational, etc.) before the program begins.
LAB ATTIRE AND PERSONAL PROTECTIVE EQUIPMENT (PPE)
- The minor should be instructed to wear closed-toed shoes and long pants to the lab/shop or change into them before entering the lab/shop. This is especially relevant in hot weather.
- The lab/shop is responsible for providing the appropriate PPE (safety glasses, gloves, lab coat, etc.) based on the Hazard Assessment. Verify that the minor’s PPE fits correctly and is comfortable. The best way to ensure that the student wears PPE is by the supervisor’s example (wear it yourself), and by the enforcement of the PPE requirements with all other lab members.
- The DLC is responsible for the cost of any personal protective equipment for the minor.
The following process is for minors, who plan to work in a lab, shop or similar area. It can be used for an individual minor, a class or other large group of minors.
- Identify who will be the primary supervisor and the alternate. Review supervision guidelines and confirm that the primary supervisor and the alternate supervisor will be committed to fulfilling the responsibilities required, most importantly, close supervision of the minor.
- UROPs should not be assigned to be a supervisor, per the UROP policy. Clarify the time commitment because the role of the supervisor is to provide close supervision.
- Check if your EHS Coordinator and AO have tailored the Hazard Assessment template and reveiw process for your DLC. Determine who your EHS Coordinator is here. If no Hazard Assessment is avalable, download the Hazard Assessment forms and add information about the EHS aspects of this project.
- Email draft assessment to your EHS Coordinator and AO/PA. If your DLC doesn't have an EHS Coordinator, the supervisor should email the draft hazard assessment to firstname.lastname@example.org. We will contact the direct supervisor to schedule an evaluation of the tasks and the work area.
- Collaborate with your EHS Coordinator to complete the hazard assessment and any action items.
- Save the final version if you plan to sponsor high/ middle school students in the future.
- Please do not send these forms to the parents before the EHS review has been completed.
- All steps of this process are required to be completed and submitted to the MIT DLC AO or their designee before the minor can be on campus unaccompanied by their parent/guardian.
- Ask the AO to get an MIT ID for the minor if the PI will pay the $10 fee. An MIT ID/Kerberos ID is required for online access to EHS training.
WHAT TO DO IF ACCIDENTS/INCIDENTS OCCUR
- Bring the Parental Consent/Medical & Emergency Contact form when accompanying the minor to MIT Urgent Care or if the minor is taken by ambulance to a local hospital.
- Call the parent/ guardian ASAP. The contact information is on the Parental Consent/Medical & Emergency Contact form.
- Complete the Supervisor’s Injury Report electronic form.
- Incidents not resulting in injury: If the minor was not injured but could have been injured, send a description of the incident to the School or DLC EHS Coordinator and EHS Office.
- Incidents not witnessed or reported at the time of occurrence: If the parent reports to a supervisor that an injury did occur, then submit the Supervisor’s Injury Report including the facts known and parent’s account.
- Provide assistance when an incident is investigated.
- It is important that the AO and EHS Coordinator collaborate on this process and tailor the hazard assessment template, the roles and the responsibilities for their DLC.
- Fill in the return address (in the parents section of the hazard assessment form) so the parents can mail the original hard copy of the signed forms to the DLC headquarters office.
- Delete these instructions before the AO or primary supervisor emails the forms to the parents so they can sign these. For class trips with EHS hazards, email the forms to the teacher, who can distribute the forms to the parents. The teacher can collect the forms and give these to the primary supervisor on the day of the class trip. Please do not send these forms to the parents before the EHS review has been completed.
The AO or HR Administrator for the DLC is responsible for distributing and retaining the signed paperwork (consent/waiver/medical, hazard assessment). Also keep a folder of all paperwork in your Headquarters, in case there is an incident involving the minor.
- The AO or Primary Supervisor must follow the security guidelines at http://ist.mit.edu/security/compliance
If a high school contacts your DLC or a PI directly regarding programs for their students, encourage them to consider instead the existing outreach programs listed in the PSC’s MIT Outreach Directory. If your DLC decides to work with the high school, we suggest working out the internal issueswith your stakeholders before starting the EHS review
1. Review the hazard assessment and if you have questions or concerns, contact the primary supervisor.
2. Print, fill in the information, and sign the forms
3. Mail the hard copy of the signed forms to:
MIT Dept of ____________
Attention: Administrative Officer/ HR Administrator
Building # - room #
77 Mass Ave.
Cambridge, MA 02139
Do not email or fax because this is confidential. Alternative: The student can hand deliver the forms.