The policies and guidelines for the protection of minors at MIT not only include the procedures described on the Protection of Minors site, but also specific EHS-related procedures as described below.
The EHS specific procedures on this page were developed in collaboration with Risk Management & Compliance Services, the Office of General Counsel, Human Resources, and the EHS Office. They add an additional level of protection for individuals and/or groups of minors that will be involved in activities, or using equipment or tools within labs, shops and other areas (e.g., maker spaces) that may have health and safety related hazards (collectively, the “EHS-related risks”).
NOTE: If you are new or unfamiliar with the process of hosting/hiring minors, you should first review the Protection of Minors site which explains the requirements and procedures that apply to all minors (the MIT Policy on the Employment of Minors, Registration, Background Checks, Supervision, Safety, Reporting of Abuse or Neglect, Do’s and Don’ts of Working with Minors). Prior to hiring or agreeing to host a minor or high school student, the primary supervisor should also verify whether there are any specific approval processes required by their DLCI.
Scope
The scope of these EHS procedures include any job, internship, program, project, etc. associated with MIT, in which minors and high school students will be involved, regardless of whether they are paid or unpaid or accompanied by parents/chaperones. Although the EHS Office is available to review any type of activity involving minors and high school students, our primary focus is on the EHS-related risks.
Who is covered by the EHS procedure?
Any minor- For the purposes of this guidance, a minor is anyone under the age of 18 who is not enrolled at MIT. This includes, without limitation: (1) students from other colleges who are under 18, even if they have an appointment to work for a PI in a lab/shop (paid or unpaid); (2) minors who may receive materials to undertake some activity under an MIT program with EHS-related risks.
High school students who are 18 or older and who are working in areas and/or will be doing activities with EHS-related risks, regardless of location.
This EHS procedure does not apply to the following:
High School students who have been accepted at MIT and are participating in Campus Preview Weekend (CPW), as CPW, or other similar pre-admissions are programs sponsored by the MIT Office of Undergraduate Admissions (OUA), and participants are managed by the OUA, with assistance from EHS, the Office of Insurance, and Division of Student Life.
Minors working in off-campus locations managed by an external organization collaborating with MIT. The supervisor should still contact the MIT EHS Office and minors@mit.edu for general guidance.
Principal Investigator, Supervisor, or EHS Rep Guidance
It is very important to understand that the DLCI Director, Administration and Finance (DAF) and/or HR Administrator (HRA) needs to be involved in almost every step of the minor hiring process. As soon as you start to consider hiring or hosting a minor, reach out to your DAF or HRA for guidance and collaboration.
The DAF/HRA for the DLCI is responsible for distribution and collection of all required paperwork (consent form, waivers, health questionnaire, etc.). Additionally, the DAF/HRA shall make sure a copy of the completed and signed EHS Hazard Assessment is returned to parents/guardians for their awareness.
The DAF/HRA is responsible for keeping a folder (computer and/or paper) of all completed and signed paperwork in a secure location and/or password protected (if e-files), accessible to the limited DLCI contacts who need to know, in case there is an accident.
It is important that the DAF/HRA and EHS Coordinator collaborate on the review process and, if appropriate, tailor the hazard assessment template, based on the hazards, roles and the responsibilities for their DLCI.
The main EHS-related responsibilities of Principal Investigators (PIs), program sponsors, and supervisors (areas that have EHS-related risks):
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 PI of the host DLCI is responsible for the minor or high school student even when they are working in another PI’s lab or work area. This includes spaces that do not have a dedicated PI, but instead have a staff member supervising 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 risks, and shall designate someone to assume the EHS rep role. The space owners share responsibility for providing a safe physical environment for the programs that are conducted in their areas.
This guidance is intended to foster a safe environment and prevent exposure to hazardous materials, lab-acquired infections, injuries, etc.
EHS Process Considerations when Hiring or Hosting a Minor
The following considerations apply when minors and high school students, whether individually or in groups, plan to work in areas or on activities that have EHS-related risks.
Identify who will be PI/ director, the primary supervisor and the alternate supervisor. All of these people should review the Supervision and Not Working Alone guidelines below.
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.
Review the Hazard Assessment and Training guidelines below and fill out the appropriate hazard assessment form, but do not sign. 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.
NOTE: The initial draft of the Hazard Assessment Form should be emailed to your EHS Coordinator at least one month prior to start date, to allow adequate time for review and modification.
Please review the Lab Attire and Personal Protective Equipment (PPE) and What to do if an Incident or Injury Occurs guidelines below, before the minor(s) start date.
Please refer to the General Guidance for Supervising Minors. 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 from working alone under any circumstances, even if they are only using the computer. There are no situations where it is appropriate for minors and high school students to work (or be on campus) if they are unsupervised.
Who Can Supervise Minors
Current MIT faculty, postdoctoral associates, researchers, graduate students and/or other appropriate employees of MIT may serve as supervisors.
Who May Not Supervise Minors
Undergraduate students.
Non-MIT employees (e.g., postdoctoral fellows, independent contractors, staff from temporary agencies like MITemps)
The primary and/or alternate supervisors must closely supervise the minor/high school student by working with or near them at all times, (i.e. line of sight or within earshot). If both the primary and alternate supervisors are not available, then the minor/high school student cannot be in the work area or on campus.
Minors and high school students shall not be given keys, card access, punch codes or other means that allow access to work locations. Any of these access methods could potentially allow minors and high school students to work alone.
NOTE: Working alone exception for undergraduates and UROPs does not apply to minors and high school students.
Supervision Ratio when using hazardous materials or equipment:
The hazard assessment should include the following recommended ratios, depending on the severity of hazard and the potential for injury:
1 supervisor: 1 or 2 minors/high school students, if the risk of an injury is moderate.
1 supervisor: 3 or more minors/high school students, if the risk of an injury is low.
A documented hazard assessment of the minor’s/ high school student’s work and work area must be conducted, to determine what tasks can/cannot be done, what 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 material or equipment. This includes the common hazards at MIT that are not included in the Summary of Federal and Massachusetts Laws.
The documented hazard assessment is required to be completed, signed, and submitted to the DLCI DAF or Program Administrator before the minor/high school student can be on campus unaccompanied by their parent/guardian and/or prior to the project’s start date.
If during the course of their work, the minor/high school student will work in another PI or supervisor’s lab, shop, work area, then a new assessment should be added to the original documented hazard assessment as an addendum.
All signed hazard assessments for programs, (i.e. RSI and Science Club for Girls), which assign students to work in different DLCIs’ labs, should be sent to the program administrator/director. The documented hazard assessment for each student should be filed with their other legal/medical forms. Each program is responsible for retaining the forms in their custody for a period of three years and should have a plan to regularly destroy such materials upon the expiration of that time frame.
The PIs, directors, and supervisors shall require that minors/high school students whom they hire or host have completed all applicable EHS training before they 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, as well as those listed on the Minors website) before the program, internship, job, etc. begins.
NOTE: Listed Supervisors must take/be up to date on all the training courses that the minor is expected to take.
The EHS Coordinator and/or EHS Office should confirm the training status of all of the minors/high school students and supervisors.
Web-Based Training
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 obtain their Kerberos ID and their MIT Personal Certificates, which will enable them to sign up for ATLAS courses.
NOTE: When setting up the guest account, DO NOT check off allowing for physical campus access.
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 (i.e., wear it yourself), and by the enforcement of the PPE requirements with all other lab members.
The PI, shop supervisor, or the DLCI is responsible for the cost of any personal protective equipment for the minor/high school student.
The responsible Principal Investigators, Program Sponsors, and Supervisors should 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 transported by ambulance to a local hospital.
Review the hazard assessment and if you have questions or concerns, contact the primary supervisor directly.
Programs Run by Undergraduate Students Involving Activities in Labs, Workshops or Makerspaces
NOTE: An MIT undergraduate student cannot be solely responsible for or in any way supervise an MIT student-run outreach program for minors when it involves EHS-related risks.
If a recognized student group is interested in creating a new outreach program that involves placing minors and high school students in areas or undertaking activities that have EHS-related risks, regardless of location, they will need to do the following:
Meet with the Student Organizations, Leadership and Engagement Office (SOLE) to discuss the proposal.
Meet with and/or email the DSL EHS Coordinator to complete the safety plan review.
SOLE staff person or a graduate student supervises the activities with EHS-related risks.
Makerspaces in Dorms: High School students cannot enter these areas except during CPW. They may only use certain hand and power tools, not machine tools. The MIT students must pre-cut items and perform other tasks in advance, to make the activity safer.
The recognized student group must find a faculty member, PI, or staff member of the DLCI who will be responsible for the minor/high school student program in their lab space. The faculty member or PI could also get approval for the program to use the DLCI’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 another experienced member of their lab group to be the on-site supervisor. This individual is responsible for compliance with the safety plan and proper disposal of any hazardous waste.
The above roles and process are the same for DLCI-run shops and makerspaces. For the purposes of the EHS Management System, the responsible supervisor/manager is the PI.
The approval process for makerspaces, which are student-run, will start with the EHS review and additional steps will be identified.
If you are an EHS Lead Contact or DLCI EHS Coordinator, please login for additional guidance to assist your DLCIs with this process. After logging in, if you do not see the additional content, EHS Coordinator and Lead Contact Guidance, please contact ehs-it@mit.edu.
Overview
The policies and guidelines for the protection of minors at MIT not only include the procedures described on the Protection of Minors site, but also specific EHS-related procedures as described below.
The EHS specific procedures on this page were developed in collaboration with Risk Management & Compliance Services, the Office of General Counsel, Human Resources, and the EHS Office. They add an additional level of protection for individuals and/or groups of minors that will be involved in activities, or using equipment or tools within labs, shops and other areas (e.g., maker spaces) that may have health and safety related hazards (collectively, the “EHS-related risks”).
NOTE: If you are new or unfamiliar with the process of hosting/hiring minors, you should first review the Protection of Minors site which explains the requirements and procedures that apply to all minors (the MIT Policy on the Employment of Minors, Registration, Background Checks, Supervision, Safety, Reporting of Abuse or Neglect, Do’s and Don’ts of Working with Minors). Prior to hiring or agreeing to host a minor or high school student, the primary supervisor should also verify whether there are any specific approval processes required by their DLCI.
Scope
The scope of these EHS procedures include any job, internship, program, project, etc. associated with MIT, in which minors and high school students will be involved, regardless of whether they are paid or unpaid or accompanied by parents/chaperones. Although the EHS Office is available to review any type of activity involving minors and high school students, our primary focus is on the EHS-related risks.
Who is covered by the EHS procedure?
Any minor- For the purposes of this guidance, a minor is anyone under the age of 18 who is not enrolled at MIT. This includes, without limitation: (1) students from other colleges who are under 18, even if they have an appointment to work for a PI in a lab/shop (paid or unpaid); (2) minors who may receive materials to undertake some activity under an MIT program with EHS-related risks.
High school students who are 18 or older and who are working in areas and/or will be doing activities with EHS-related risks, regardless of location.
This EHS procedure does not apply to the following:
High School students who have been accepted at MIT and are participating in Campus Preview Weekend (CPW), as CPW, or other similar pre-admissions are programs sponsored by the MIT Office of Undergraduate Admissions (OUA), and participants are managed by the OUA, with assistance from EHS, the Office of Insurance, and Division of Student Life.
Minors working in off-campus locations managed by an external organization collaborating with MIT. The supervisor should still contact the MIT EHS Office and minors@mit.edu for general guidance.
Principal Investigator, Supervisor, or EHS Rep Guidance
It is very important to understand that the DLCI Director, Administration and Finance (DAF) and/or HR Administrator (HRA) needs to be involved in almost every step of the minor hiring process. As soon as you start to consider hiring or hosting a minor, reach out to your DAF or HRA for guidance and collaboration.
The DAF/HRA for the DLCI is responsible for distribution and collection of all required paperwork (consent form, waivers, health questionnaire, etc.). Additionally, the DAF/HRA shall make sure a copy of the completed and signed EHS Hazard Assessment is returned to parents/guardians for their awareness.
The DAF/HRA is responsible for keeping a folder (computer and/or paper) of all completed and signed paperwork in a secure location and/or password protected (if e-files), accessible to the limited DLCI contacts who need to know, in case there is an accident.
It is important that the DAF/HRA and EHS Coordinator collaborate on the review process and, if appropriate, tailor the hazard assessment template, based on the hazards, roles and the responsibilities for their DLCI.
The main EHS-related responsibilities of Principal Investigators (PIs), program sponsors, and supervisors (areas that have EHS-related risks):
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 PI of the host DLCI is responsible for the minor or high school student even when they are working in another PI’s lab or work area. This includes spaces that do not have a dedicated PI, but instead have a staff member supervising 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 risks, and shall designate someone to assume the EHS rep role. The space owners share responsibility for providing a safe physical environment for the programs that are conducted in their areas.
This guidance is intended to foster a safe environment and prevent exposure to hazardous materials, lab-acquired infections, injuries, etc.
EHS Process Considerations when Hiring or Hosting a Minor
The following considerations apply when minors and high school students, whether individually or in groups, plan to work in areas or on activities that have EHS-related risks.
Identify who will be PI/ director, the primary supervisor and the alternate supervisor. All of these people should review the Supervision and Not Working Alone guidelines below.
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.
Review the Hazard Assessment and Training guidelines below and fill out the appropriate hazard assessment form, but do not sign. 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.
NOTE: The initial draft of the Hazard Assessment Form should be emailed to your EHS Coordinator at least one month prior to start date, to allow adequate time for review and modification.
Please review the Lab Attire and Personal Protective Equipment (PPE) and What to do if an Incident or Injury Occurs guidelines below, before the minor(s) start date.
Please refer to the General Guidance for Supervising Minors. 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 from working alone under any circumstances, even if they are only using the computer. There are no situations where it is appropriate for minors and high school students to work (or be on campus) if they are unsupervised.
Who Can Supervise Minors
Current MIT faculty, postdoctoral associates, researchers, graduate students and/or other appropriate employees of MIT may serve as supervisors.
Who May Not Supervise Minors
Undergraduate students.
Non-MIT employees (e.g., postdoctoral fellows, independent contractors, staff from temporary agencies like MITemps)
The primary and/or alternate supervisors must closely supervise the minor/high school student by working with or near them at all times, (i.e. line of sight or within earshot). If both the primary and alternate supervisors are not available, then the minor/high school student cannot be in the work area or on campus.
Minors and high school students shall not be given keys, card access, punch codes or other means that allow access to work locations. Any of these access methods could potentially allow minors and high school students to work alone.
NOTE: Working alone exception for undergraduates and UROPs does not apply to minors and high school students.
Supervision Ratio when using hazardous materials or equipment:
The hazard assessment should include the following recommended ratios, depending on the severity of hazard and the potential for injury:
1 supervisor: 1 or 2 minors/high school students, if the risk of an injury is moderate.
1 supervisor: 3 or more minors/high school students, if the risk of an injury is low.
A documented hazard assessment of the minor’s/ high school student’s work and work area must be conducted, to determine what tasks can/cannot be done, what 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 material or equipment. This includes the common hazards at MIT that are not included in the Summary of Federal and Massachusetts Laws.
The documented hazard assessment is required to be completed, signed, and submitted to the DLCI DAF or Program Administrator before the minor/high school student can be on campus unaccompanied by their parent/guardian and/or prior to the project’s start date.
If during the course of their work, the minor/high school student will work in another PI or supervisor’s lab, shop, work area, then a new assessment should be added to the original documented hazard assessment as an addendum.
All signed hazard assessments for programs, (i.e. RSI and Science Club for Girls), which assign students to work in different DLCIs’ labs, should be sent to the program administrator/director. The documented hazard assessment for each student should be filed with their other legal/medical forms. Each program is responsible for retaining the forms in their custody for a period of three years and should have a plan to regularly destroy such materials upon the expiration of that time frame.
The PIs, directors, and supervisors shall require that minors/high school students whom they hire or host have completed all applicable EHS training before they 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, as well as those listed on the Minors website) before the program, internship, job, etc. begins.
NOTE: Listed Supervisors must take/be up to date on all the training courses that the minor is expected to take.
The EHS Coordinator and/or EHS Office should confirm the training status of all of the minors/high school students and supervisors.
Web-Based Training
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 obtain their Kerberos ID and their MIT Personal Certificates, which will enable them to sign up for ATLAS courses.
NOTE: When setting up the guest account, DO NOT check off allowing for physical campus access.
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 (i.e., wear it yourself), and by the enforcement of the PPE requirements with all other lab members.
The PI, shop supervisor, or the DLCI is responsible for the cost of any personal protective equipment for the minor/high school student.
The responsible Principal Investigators, Program Sponsors, and Supervisors should 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 transported by ambulance to a local hospital.
Review the hazard assessment and if you have questions or concerns, contact the primary supervisor directly.
Programs Run by Undergraduate Students Involving Activities in Labs, Workshops or Makerspaces
NOTE: An MIT undergraduate student cannot be solely responsible for or in any way supervise an MIT student-run outreach program for minors when it involves EHS-related risks.
If a recognized student group is interested in creating a new outreach program that involves placing minors and high school students in areas or undertaking activities that have EHS-related risks, regardless of location, they will need to do the following:
Meet with the Student Organizations, Leadership and Engagement Office (SOLE) to discuss the proposal.
Meet with and/or email the DSL EHS Coordinator to complete the safety plan review.
SOLE staff person or a graduate student supervises the activities with EHS-related risks.
Makerspaces in Dorms: High School students cannot enter these areas except during CPW. They may only use certain hand and power tools, not machine tools. The MIT students must pre-cut items and perform other tasks in advance, to make the activity safer.
The recognized student group must find a faculty member, PI, or staff member of the DLCI who will be responsible for the minor/high school student program in their lab space. The faculty member or PI could also get approval for the program to use the DLCI’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 another experienced member of their lab group to be the on-site supervisor. This individual is responsible for compliance with the safety plan and proper disposal of any hazardous waste.
The above roles and process are the same for DLCI-run shops and makerspaces. For the purposes of the EHS Management System, the responsible supervisor/manager is the PI.
The approval process for makerspaces, which are student-run, will start with the EHS review and additional steps will be identified.
If you are an EHS Lead Contact or DLCI EHS Coordinator, please login for additional guidance to assist your DLCIs with this process. After logging in, if you do not see the additional content, EHS Coordinator and Lead Contact Guidance, please contact ehs-it@mit.edu.