These Requirements were developed as part of the Minors policy initiative and must be followed pursuant to the Policy for Programs Involving Minors (the “Policy”). All capitalized terms are defined in the Policy.
I. Purpose
This document is a supplement to Princeton University’s Policy for Programs Involving Minors and is intended to provide information on what activities are considered appropriate for the involvement of a Minor and clarity related to activities in Research Facilities, defined in the Policy as “any facility used for the purpose of conducting research and/or experiments. For the purposes of this policy, a Research Facility may include or be adjacent to hazardous operations, hazardous equipment and/or materials, machinery, or field research.”
II. Who is Affected
These Rules and Procedures apply to Adults who work within a Research Facility, and to all Minors who may enter or participate in activities within any University Research Facility.
III. Definitions
Biological Agent: A biological material capable of causing disease in humans. Biological agents include bacteria, viruses, fungi, other microorganisms and their associated toxins, that can adversely affect human health.
Established Educational Program: Any University-sponsored or hosted program established for the purpose of providing an educational experience, including but not limited to, Office of the Dean for Research Laboratory Learning Program, Princeton University Preparatory Program (PUPP), or any properly scheduled, approved and supervised open house or tour.
Hazardous Chemical: Any chemical which is a "health hazard" or "physical hazard," including but not limited to: chemicals that are carcinogens, toxic agents, irritants, corrosives, combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive.
Laboratory Learning Program (LLP): Program offered to select high school students who are at least 16 years old, designed to provide an educational environment that allows them to conduct research under the mentorship of Princeton faculty, staff, and students. The program is administered by the Office of the Dean for Research. Research opportunities are proposed by hosting laboratories, which are then reviewed and approved by Princeton University’s Office of Environmental Health and Safety (EHS).
Mandatory Training: Training specified by EHS, the academic unit, program, and/or supervisor as a requirement for an individual to be present in a research facility, or conduct research in a facility.
Prohibited Activity: Use of any of the following materials, considered by definition to be hazardous operations according to the State of New Jersey Department of Labor, is not permitted by Minors.
- Radioactive Material
- X-ray/Radiation Producing Equipment
- Hazardous Chemicals
- Biological Agents (Laboratory Learning Program proposals that include work with well-characterized biological materials that do not cause disease in healthy humans, and which qualify for study under biosafety level 1 (BSL-1) laboratory practices are permitted.)
- Energized Equipment (electrical, high pressure/vacuum, etc.)
- Class 3 or 4 Lasers
Supervision: Oversight, instruction and direction provided by an Adult having knowledge of the potential hazards in a laboratory or research activity.
IV. Rules and Procedures
A. Princeton University does not permit Minors to be employed (paid or unpaid) in research facilities. This requirement follows New Jersey child labor laws that restrict Minors from employment in hazardous environments such as laboratories and further restrict nearly all activities involving hazardous materials and procedures.
B. Princeton University does not permit Minors to engage in any Prohibited Activity.
C. Persons under the age of 18 are allowed in Research Facilities with supervision and Mandatory Training, only under the following limited circumstances:
- The Minor is at least 16 years old and is participating in the Laboratory Learning Program on a project approved by EHS and the Dean for Research. The Laboratory Learning Program is an educational program for the benefit of the participating students under the close supervision of laboratory personnel.
- The Minor is a visitor to the Research Facility in the context of a properly scheduled, approved and supervised open house or tour.
- The Minor is participating in a University-sponsored educational program for which EHS has reviewed procedures and required training (provided by EHS or instructors associated with the program). All participants must receive Mandatory Training and exercise safety precautions commensurate with the experimental procedures and materials in use.
- Minors may be escorted through potentially hazardous areas to reach office areas or other non-hazardous areas if they are in the presence of and under the close supervision of an adult cognizant of the hazards present in that area. Personal desk area/write-up spaces within the envelope of the research area (e.g., laboratory) are considered to be, themselves, Research Facilities regardless of degree of proximity to, and/or separation distance from lab benches, chemical storage or use areas, etc. Individuals should seek permission from their supervisor to bring their child or children into the workplace.
Rationale:
Minors are prohibited from entering Research Facilities or other areas where potentially hazardous conditions exist because:
- Minors are generally more susceptible than adults to hazardous chemicals, radiation and hazardous biological agents.
- Minors are less aware of the potential hazards in specific workplaces and are more likely to do something inappropriate.
- The workplace is often disrupted by unpredictable activities when Minors are present, since those supervising the Minors have to multitask between work and child care, and people sharing space with Minors are distracted by unusual activities.
V. Related Policies
Laboratory Training Policy - https://ehs.princeton.edu/about-ehs/university-safety-policies/Laboratory-Training
*(Adopted August 2000 by the University Research Board)
VI. Resources
Back-up Care Advantage Program - provides faculty, staff and graduate students with back-up care when you experience temporary disruptions in your child, adult and elder caregiving arrangements that would otherwise prevent you from fulfilling work or study obligations.
Environmental Health and Safety Website: Minors in the Laboratory
EHS Laboratory Safety Manual
VII. Update Log
– effective 9/3/2019