February 2015 update:
We encourage EHS Coordinators to work with your department head, through your EHS Committee, your local Human Resources Administrator, and/or AO as is appropriate to do the following.
Possible actions from your department head/ senior administrators are:
- Send a reminder to the PIs that describes your specific procedures, instead of the generic message from Human Resources. If you have tailored the hazard assessment form for your DLC, then attach it or include the link if it is posted on your DLC website.
- Put this topic on the agenda for a faculty meeting.
What you can do:
- Check that you have included the latest versions of all the applicable forms with your version of the hazard assessment form. These will be linked from the EHS and HR sites.
- Review your specific procedures during meetings or trainings with your PIs.
- Put this topic on the agenda for an EHS rep meeting.
- If applicable, highlight your additional local guidelines and your review process to address any exceptions or one-off situations in all of the above meetings.
- If you would like to tailor the hazard assessment template and the process, please review the steps in the next section.
Suggestions for tailoring the template and review process:
- Insert your DLC name and your name/ title throughout the template.
- Insert the training courses that you require every minor to take and the delivery option (web, live, or both) that your labs should use.
- Modify the working with the hazardous materials/ equipment section so it is applicable to your labs and reflects your process.
- Edit the Approval section based on what signatures you require and clarify if your DLC uses email as an alternative.
- Delete the instructions about tailoring the template.
- Paste the latest versions of the common legal and other forms, which your labs will use, into your version of the template. Delete the Biological and Radiation forms if these don’t apply.
When you receive a request to hire/ host a minor:
- Review the draft hazard assessment and refer to the guidelines about Hazards that Minors can and can't work with.
- The team will review the results of the latest inspection and any issues that the EHS rep and others have raised recently. They will follow up on the status of these issues during the lab visit to review the minor’s project. They will determine if these issues are important to ensure the safety of the minor as well as other lab members. They will also confirm that the training status of the primary and alternate supervisors is current because they will train the minor and will need to reinforce safe practices/ procedures from the training courses.
- Work with the AO, PI, Primary Supervisor, EHS Deputy Director, etc. to finalize this assessment. This may involve checking the training records and the status of the inspection findings, visiting the lab or work area, discussing this with the PI and the Primary Supervisor, etc. Note: This assessment must be included with the forms that the parent signs
- Send the final version to the PI, Primary supervisor, AO and others, who are involved in this process.
- Document the EHS review (Note: 4 signatures are no longer required)
The final version of this Hazard Assessment shall be reviewed and approved by the Principal Investigator. Email is acceptable in the interim until the PI is back on campus and can sign the form. If the Primary Supervisor is not the PI, then they also have to review and approve by sending an email. Either the EHS Coordinator and/or the EHS Lead Contact will also indicate that they have reviewed this. Note that EHS does not have an approval role. Other roles can be added if this is the DLC preference.
Best option: PI and designees sign the hard copy of assessment.
Alternative: People, other than the PI who are involved, indicate they have reviewed/ approved via email. Complete the list of Names and dates of emails.
For the Lead Contact: Save the final version in the Minors folder, M drive template using this Naming convention: PI name_ Student name_MM_YYYY
Who is a Minor
Anyone under the age of 18 who is not an enrolled MIT student
High/ Middle School students under the age of 18, who will be working with hazardous materials, or engaged in hazardous activities in a research laboratory/ shop.
High School students, who are 18 years old, and are living at home with parents/ guardians
Covered programs include long term projects as well as short visits that involve hands on activities (class trips, tours). Also any programs involving minors that are organized by MIT students using MIT facilities.
The EHS Office will contact Regina Dugan in the Office of General Counsel about any other unusual situations.
Refer to the detailed explanation of the legal and HR issues about various types of minors.
Situations where a less formal assessment may be appropriate
In some cases, depending on the minor’s project and the nature and severity of the hazards present in a particular work area, a less formal hazard assessment process may be appropriate. For example, if a project involves a minor who will be working solely in an office on a computer, it may not be necessary to fill out the hazard assessment form. In this situation, if the EHS Coordinator is familiar with the work area and can verify that hazards are minimal, it may suffice for the EHS Coordinator to remind the supervisor about the importance of providing training on emergency evacuation, response to injuries, and preventing computer-related repetitive strain injuries. Similarly, a project that is repeated from year to year without significant changes may not warrant a detailed review each year. A quick review by the EHS Coordinator to confirm that nothing significant about the project and the lab has changed, and a reminder to the Principal Investigator and supervisor about supervisory and training responsibilities may suffice. If a new supervisor takes over responsibility for supervising a project, a meeting with the new supervisor may be scheduled by the EHS Coordinator or Lead Contact to review the hazard assessment form, including guidelines that have been set, training, and supervisory responsibilities.