Purpose

The purpose of this policy is to provide guidance to faculty members, researchers, managers, and supervisors of laboratories and programs regarding underage individuals (minors) in University of Alabama at Birmingham (UAB) research laboratories or facilities where physical hazards exist, where hazardous chemical, biological, or radiological agents are used or stored, or where laboratory animals are present. 

Definitions

1. "Minor" is defined for purposes of this policy as any individual under 18 years of age.
2. For purposes of this policy, a "designated supervisor" is a UAB employee who is directly responsible for overseeing the presence and involvement of the minor at UAB. The designated supervisor need not have an advanced degree but must be thoroughly familiar with the work in which the minor is involved at UAB. The designated supervisor should be familiar with UAB policy that governs the minor’s involvement at UAB.

Scope

1. This policy covers all UAB laboratories and animal activity areas (facilities, procedure rooms, and housing areas).
2. For purposes of this policy, the term "laboratories" also includes field study sites even if off campus.
3. This policy includes all persons under age 18, with the exception of:
   1. Minors enrolled at UAB who are participating in laboratory activities as part of their course work or undergraduate program requirements or who are observing in laboratories or animal facilities as part of their course work. Each faculty member/researcher or designated supervisor is required to provide such student with appropriate safety instructions.
   2. Minors who are employees of UAB and whose employment responsibilities are in UAB laboratories. Employment of such individuals must be processed through Human Resource Management. (See HRM Policy 125 "Employment of Minors.")
   3. Minors who are subjects in studies approved by an Institutional Review Board designated by UAB.
   4. Minors in non-research-related UAB University Hospital laboratories. Those laboratories are under the purview of the Hospital Safety Committee.

Policy

1. Unless enrolled as a UAB student, minors are not allowed to conduct research, or observe in UAB research laboratories or animal activity areas except as identified specifically below.
2. All minors are prohibited from entering the following areas:
   1. Any laboratory or animal activity area designated as BSL-3, ABSL-3, or higher for recombinant or infectious organisms.
   2. Any laboratory or animal activity area where select agents or explosives are used or stored. (Explosives are defined for purposes of this policy as any chemical compound, mixture, or device, the primary or common purpose of which is to function by explosion, i.e., with substantially instantaneous release of gas and heat and which meets the federal requirements to be labeled as an explosive.)

3. Minors are prohibited from working with any of the following materials:
   1. Radioactive materials or radiation (x-rays).
   2. Acute toxins.

4. Minors less than 10 years of age and not enrolled in grade four or higher are not allowed in UAB laboratories or animal activity areas where there are physical hazards, where hazardous chemical, biological, or radiological agents are used or stored, or where laboratory animals are present.
5. Minors, with the restrictions listed above, are allowed to visit, observe, or conduct research in laboratories if the following requirements are met in full:
   1. This UAB policy, Minors in Laboratories and Animal Facilities, has been read and signed by the faculty member/researcher with responsibility for activities in the laboratory or the Animal Resources Program (ARP) Director.
   2. The minor’s parent or legal guardian has read and signed a UAB Parent/Guardian Consent for a Minor in Laboratories or Animal Facilities. The form must be submitted to the Office of the UAB Vice President for Research and Economic Development prior to the minor entering the laboratory or animal facility.
   3. The minor has completed hazard specific safety training approved by UAB Environmental Health and Safety and provided by the faculty member/researcher or ARP Director. Such training will include safety-related practices and procedures as required for the laboratory including evacuation procedures and use of protective clothing or equipment.
   4. If there will be laboratory animals in the laboratory or facility, training requirements determined by the Institutional Animal Care and Use Committee must be met, but the minor must not be allowed to come into physical contact with live laboratory animals.
   5. Personal protective equipment specific to the hazard is provided to the minor with instructions for use and disposal.
   6. The minor is directly supervised by the faculty member/researcher or designated supervisor at all times while in the laboratory or animal facility.
   7. The laboratory is in full compliance with all applicable UAB safety programs and regulations.

6. The faculty member/researcher, laboratory manager, or designated supervisor may place additional restrictions on the presence of minors in their specific activity areas.
7. Minors who accompany UAB employees to the UAB workplace for reasons other than participation in UAB research-type activities are not permitted in UAB research laboratories or animal facilities. Admittance to other UAB areas is subject to approval by the appropriate dean, director, or department chair.

Implementation and Authorization

1. The Vice President for Research is responsible for procedures to implement this policy.
2. The faculty member/researcher (or ARP Director in the case of animal facilities) is responsible for all activities in the laboratory or field site while the minor is present. Delegation of activities relative to the minor’s presence to a designated supervisor does not eliminate the responsibility of the faculty member/researcher (or the ARP Director).
3. Specific authorization on a case-by-case basis for a minor to be in situations as indicated in this policy is not required from UAB Environmental Health and Safety or from the UAB Office of Risk Management and Insurance. However, UAB Environmental Health and Safety should be consulted if there are questions concerning whether or not a condition is present in a laboratory or facility that would come under this policy.
4. Exceptions to this policy must receive prior written approval from the UAB Vice President for Research or the appropriate designee. Changes in the supervision, procedures, protocols, or planned exposures require re-approval.

Non-compliance

Non-compliance must be reported to the UAB Vice President for Research. Failure to comply with the conditions of this policy may result in the immediate removal of the minor(s) from the laboratory until corrective actions have been taken.

References

1. Exposure to Minors, U.S. Nuclear Regulatory Commission, Rules and Regulations, Title 10, Chapter 1, Code of Federal Regulations, Energy Standards for Protection Against Radiation, Part 20.
2. Biosafety in Microbiological and Biomedical Laboratories, U.S. Department of Health and Human Services, Centers for Disease Control, and National Institutes of Health, Health and Human Services Publication No. (CDC) 84-8395 1^stEdition, March 1984.
3. U.S. Department of Labor, Title 29, Code of Federal Regulations, Parts 570 and 1910.