Hire/ Host A Minor or High School Student
- For the Principal Investigator, Supervisor, or EHS Rep
- Instructions for Administrative Officer/ HR Administrator
- Instructions for EHS Coordinators and Lead Contacts (certificate log in required)
The Standard Operating Procedure (SOP) for minors and high school students (paid and unpaid) is described below and at Protection of Minors. The guidelines and review process for individuals and groups that involve activities in labs, shops and other areas that have health- and safety-related hazards are described below. The guidelines for programs (groups) and for individual minors that do not involve health- and safety-related hazards can be reviewed at Protection of Minors. Protection of Minors includes the MIT Policy on the Employment of Minors and information on Hours, Registration, Transportation, MIT Housing, Health/Medical, and Background checks.
The Risk Management & Compliance Services, the Office of General Counsel, Human Resources, and the EHS Office collaborated to develop these guidelines. These will assist DLCs in hosting minors and high school students (paid and unpaid) at MIT. Prior to hiring or agreeing to host a minor or high school student, the primary supervisor should verify whether there are any specific approval processes required by your DLC.
The scope of the EHS SOP includes the jobs, internships, programs, projects, etc. which minors and high school students (refer to next section) will be involved in at MIT, regardless of whether they are paid or unpaid. The EHS Office is available to review any type of activity involving minors and high school students, but our primary focus is activities in labs, shops and other areas that have health and safety-related hazards.
Who is minor and who is covered by the EHS SOP?
- A minor, for purposes of this guidance, is anyone under the age of 18 who is not an enrolled MIT student. The EHS SOP also applies to high school students who are 18 or older and who are working in areas that have health- and safety-related (EHS) hazards and/or will be doing activities with EHS hazards. Also students from other colleges, who are under 18 and who have an appointment to work for a PI (paid or unpaid).
This SOP does not apply to the following:
- High School students who have been accepted and are participating in Campus Preview Weekend (CPW), as CPW activities and participants are managed by the Office of Undergraduate Admissions, with assistance from EHS, the Office of Insurance, and Division of Student Life.
- If the minor will be working in a lab off campus as part of a collaboration project, then the supervisor must contact the MIT EHS Office and email@example.com.
MIT prohibits interns under the age of 16, whether paid or unpaid. Refer to the MIT Policy on Minors as Employees or Interns for criteria on what is an internship.
Note for EHS: 16-17 year old students can work in labs, shops, and other areas that have EHS-related hazards if the appropriate supervision, precautions, training, etc. are implemented. Students, who are younger than 16 years old, are encouraged to participate in MIT outreach programs until they are 16 years old.
EHS-related Responsibilities of Principal Investigators, program sponsors, and supervisors (labs, shops, makerspaces, and other areas that have EHS-related hazards)
This guidance and the processes are intended to foster a safe environment and prevent exposure to hazardous materials, lab-acquired infections, injuries, etc. Please refer to the General Guidance for Supervising Minors and Who Can Serve as a Supervisor
- Principal investigators (PIs), program sponsors, and supervisors are responsible for the safety of the minors and high school students whom they host, just as they are responsible for the safety of their employees and MIT students. While a Primary Supervisor may be designated by the PI, the PI is still ultimately responsible for all aspects of the minor’s/ high school student’s presence in their lab or work area.
- The “host PI/supervisor” is still responsible when the minor or high school student is working in another PI’s lab or work area. This includes spaces that don’t have a PI but do have a staff member, who supervises the space.
- A faculty member, PI, supervisor, or a higher-level administrator shall be responsible for each student-run outreach program for minors, which involves EHS-related hazards, and shall designate someone to assume an EHS rep role. The space owners share the responsibility to provide a safe physical environment for the programs that are conducted in their areas.
- An MIT undergraduate student can’t be solely responsible for a student-run outreach program for minors, which involves EHS-related hazards, and cannot be a supervisor. Refer to section titled “Programs run by undergraduate students”.
SUPERVISION AND NOT WORKING ALONE
- Supervision is necessary for all minors and high school students. Principal investigators (PIs) and Supervisors must follow, and manage compliance with, MIT policy that prohibits minors and high school students, under any circumstances, from working alone in a laboratory, machine shop, makerspace, or other work area with identified environmental, health, and safety hazards, even if they are only using the computer. Refer to the guidance for supervision in non-lab areas.
- The primary supervisor and/or the alternate must closely supervise the minor/high school student, i.e., work with or near him/her in the lab/ shop, when working with hazardous materials/equipment.
- Minors and high school students should not be given keys, card access or punch codes to laboratories, shops, DCM, and other areas with identified EHS hazards. Any of these access methods would potentially allow minors and high school students to work alone in an area with hazards.
- Working alone exception for undergraduates and UROPs does not apply to minors and high school students. There are no situations where it is appropriate for minors and high school students to work alone in a lab, machine shop, makerspace). If the primary supervisor and the alternate are not available, then the minor/high school student can’t be in the lab, machine shop, or makerspace.
- Supervision Ratio when using of hazardous materials or equipment: The hazard assessment will include finalizing the ratio of supervisor: minors/high school students. We often recommend 1 supervisor: 1 or 2 minors/high school students depending on the severity of the hazard and potential injury. 1 supervisor: 3 or more minors/high school students if the risk of an injury is low. EHS staff and Coordinators will refer to the detailed precautions for each type of hazardous material or equipment. (certificate protected) Refer to the guidance for the Supervision Ratio for non-lab areas.
HAZARD ASSESSMENT AND TRAINING
- A documented hazard assessment of the minor’s/ high school student’s work and work area must be conducted to determine what tasks can/can’t be done, personal protective equipment should be worn, and what EHS training classes are needed. The EHS Coordinator and/or EHS Office will assist the PI/Supervisor, primary supervisor and EHS rep with this assessment.
- EHS staff and Coordinators will refer to the detailed precautions for many types of hazardous materials or equipment. (certificate protected) This includes the common hazards at MIT that are not included in the Summary of Federal and Massachusetts Laws.
- EHS Coordinators have modified the template and review process to fit the needs of their DLC. Contact your EHS Coordinator for the DLC-specific form.
- The documented hazard assessment, all other forms, and all steps of the process are required to be completed, signed, and submitted to the AO before the minor/high school student can be on campus unaccompanied by his/her parent/guardian and/or prior to the project’s start date.
- If the minor/high school student will work in another PI or supervisor’s lab, shop, work area, then the new assessment should be added to the original documented hazard assessment as an addendum.
- The documented hazard assessment for programs, which assign students to work in different DLCs labs, should be sent to the program administrator/director. The documented hazard assessment for each student should be filed with each student’s other legal/medical forms. Each program is responsible for retaining the forms in their custody for a period of three years after the program has ended.
- PIs, directors, and supervisors shall require that minors/high school students 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/high school students, shall complete all applicable training (EHS, legal, operational, etc.) before the program, internship, job, etc. begins.
- The EHS Coordinator and/or EHS Office should confirm the training status of all of the minors/high school students and supervisors.
The supervisor or their designee will submit a request to IS&T for guest account(s) http://ist.mit.edu/guest-accounts The end date on the MIT ID also triggers the training end date so the web-based training metrics will not be affected. The supervisor or their designee also assists the student(s) to get his/her/their Kerberos ID. Then, the student(s) have to do the following on their computer before they can log into Atlas/Learning Center.
- MIT Personal Certificates and the MIT Certificate Authority.
- Pop-up Blockers need to be disabled to access web courses.
- Flash plugin must be installed and enabled to receive web course completion. If you need assistance, please refer to https://ehs.mit.edu/site/about-training
LAB ATTIRE AND PERSONAL PROTECTIVE EQUIPMENT (PPE)
- The minor/high school student 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/high school student’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 PI, shop supervisor, or the DLC is responsible for the cost of any personal protective equipment for the minor/high school student.
The following process is for minors and high school students, who plan to work in a lab, shop, makerspace, or other areas that have EHS-related hazards. This process can be used for an individual or a group of minors/ high school students.
- Identify who will be PI/ director, the primary supervisor and the alternate supervisor. All of these people should review the supervision and no-working-alone guidelines. Confirm that the primary supervisor and the alternate supervisor will be committed to fulfilling the responsibilities required, most importantly, close supervision of the minors and high school students. UROPs should not be assigned to be a supervisor, per the UROP policy. “It is expected that UROP students will be supervised at all times while in the laboratory or other potentially hazardous environments. Therefore, a UROP student should not be assigned to be a supervisor, even of other UROPs or high school students.”
- The AO or designee will complete the process at https://minors.mit.edu/background-checks
- Obtain the Hazard Assessment form and review process that your EHS Coordinator has tailored for your DLC. Determine who your EHS Coordinator is here.
- Fil out hazard assessment form and email to your EHS Coordinator at least 1 month in advance. Collaborate with your EHS Coordinator to complete the hazard assessment and any action items. Please do not send these forms to the parents before the EHS review has been completed.
- Save the final version if you plan to sponsor high/ middle school students in the future.
- The forms can be executed on DocuSign; if the consent/release forms are e-signed by parents, Supervisor must confirm by either a phone call to, or voice mail recording from, parent or guardian, that parent has e-signed release and consents to having his/her child participate in the program at MIT.
WHAT TO DO IF ACCIDENTS/INCIDENTS OCCUR
- Bring the Parental Consent/Medical & Emergency Contact form when accompanying the minor for any first aid or urgent care services, 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 form in Atlas.
- Incidents not resulting in injury: If the minor was not injured, but could have been injured, send a description of the incident to the 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.
PROGRAMS RUN BY UNDERGRADUATE STUDENTS INVOLVING ACTIVITIES IN LABS, WORKSHOPS, OR MAKERSPACES
Note: An undergraduate student can’t do this on their own.
If recognized student group an is interested in creating a new outreach program that involves placing minors and high school students in labs, makerspaces, or workshop areas or activities that have EHS hazards will be done in non-lab/shop spaces, (s)he will need to do the following:
Steps for SAO sponsored programs and ASA recognized groups
- Complete the SAO risk assessment form (web form)
- Meet with Student Activities Office to discuss the proposal
- Meet with and/or email the DSL EHS Coordinator to complete the safety plan review.
- SAO staff person or grad student supervises the activities with EHS hazards
- Makerspaces in Dorms: High School students can’t enter these areas except during CPW. They only use certain hand and power tools, not machine tools. The MIT Students precut items and do other tasks in advance to make it safer.
Steps for science/engr. DLC sponsored programs
- The recognized student group must find a faculty member, a PI, staff member or Department, who will be responsible for the minors/high school student program in their labs. The faculty member or PI could also get approval for the program to use the DLC’s teaching lab.
- Meet with and/or email the EHS Coordinator and their team to complete the safety plan review.
- The faculty member or PI will assign their EHS rep or other experienced member of their lab group to be the on-site supervisor. Their role is to ensure that the safety plan is followed, the hazardous waste is disposed of properly, etc.
- The above roles and process are the same for DLC-run shops and makerspaces. The supervisor/manager is the PI in terms of the EHS Management system.
- The approval process for makerspaces, which are student run, will start with the EHS review and additional steps will be identified.
- It is important that the AO and EHS Coordinator collaborate on the review process and tailor the hazard assessment template, the roles and the responsibilities for their DLC.
- The AO for the DLC is responsible for distributing and retaining the signed paperwork (consent/waiver/medical, hazard assessment). Additionally, you are advised to keep a folder of all paperwork in your Headquarters, in case there is an accident.
- 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 MIT Outreach Directory. If your DLC decides to work with the high school, we suggest working out the internal issues with your stakeholders (including all facility managers) before starting the EHS review.
- Review the hazard assessment and if you have questions or concerns, contact the primary supervisor.
- Print, fill in the information, and sign the forms.
- 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.