University Policy Manual

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Minors Working with Hazardous Materials in Research Laboratories Policy 

Policy Category Issuing Authority Responsibility Publication Date Next Review Date
Environmental Health & Safety Enterprise Risk Management  Environmental Health & Safety  12/29/2025 12/29/2028

 

Policy Statement & Background:

Stony Brook University strives to promote safe science and to encourage research projects that involve youth from the community. This policy will provide guidelines to allow minors to safely work in a supervised research laboratory.  

 

Scope

This policy applies to Stony Brook University research laboratories. See definitions below for the precise identification of a research laboratory (or laboratory - for short) affected by this policy.  

 

Policy:

  • Principal Investigators, Faculty, Mentors and Supervisors have a responsibility to ensure the safety of all Minors in research laboratories. In order to provide a safe work environment, the following shall apply:

    1. No one under 14 years old will be permitted to work in a research laboratory.

    2. Minors must be supervised at all times while in a laboratory.

    3. Sponsoring Principal Investigators and Faculty/Mentors are responsible for:

      1. Advising their Department Chair (or higher authority) that Minors will be working in the laboratory; 

      2. Ensuring that training is provided, enforcing safe work practices;

      3. Providing appropriate personal protective equipment; 

      4. Ensuring appropriate supervision of the Minors. 

    4. All minors must obtain a Parent/Guardian Consent Form (Appendix A). 

    5. All minors working in research laboratories must comply with the following requirements: 

      1. Hazardous Chemicals

        1. Minors aged 14-15 years old are prohibited from working with: 

          • Particularly Hazardous Substances:

            • Acutely toxic: LD50 oral ≤ 50 mg/kg; LD50 contact ≤ 200 mg/kg or LC50 inhalation ≤ 200 ppm. 

            • Carcinogen: Any substance that is regulated by OSHA as a carcinogen, or is listed under the category "known to be carcinogens" in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) or is listed under Group 1 "carcinogenic to humans", Group 2A or 2B "reasonably anticipated to be carcinogens" by the International Agency for Research on Cancer Monographs (IARC).

            • Reproductive hazard (mutagen or teratogen) 

          • Highly hazardous chemicals such as explosives, water/air reactive chemicals, peroxide-forming chemicals that could cause serious injury or harm to people in the laboratory. 

      2. Controlled Substances

        1. Minors may not have unsupervised access to any setting where research involving controlled substances. Controlled substances are narcotic and non-narcotic substances regulated under the federal Controlled Substance Act and New York State Department of Health Part 80 Controlled Substance Regulations. 

      3. Biological materials

        1. Minors aged 14-15 years old are prohibited from working with biological materials that require BSL 2 or BSL 3 containment. 
          1. Exception: Human cells, tissue, and blood can be used as long as it is not known to be infectious. Minors must receive biological safety training, blood pathogens training, and use BSL 2 work practices and procedures for handling human material. 
        2. Minors over the age of 16 that have obtained Parent/Guardian Consent Form, completed all required EH&S training and have demonstrated to the Faculty/Mentor a proficiency in techniques and an understanding of the hazards and risks of the material, are permitted to work with biological materials requiring BSL-2 containment. 

      4. Power tools

        1. Minors under the age of 16 are prohibited from operating or assisting in operating any machinery unless all moving parts other than keys, levers, or handles are so guarded to prevent any part of the person or clothing for the operator from touching them.  

      5. Radioactive materials

        1. Minors are never authorized to work with, touch or handle radioactive materials.  
        2. Minors may take part in tours of radioactive materials areas in which the principal investigator has obtained a tour permit (Appendix B) through radiation safety. 

      6. X-ray generating equipment

        1. Minors are never authorized to make X-ray exposures. 
        2. Minors may take part in tours of areas in which X-ray generating equipment is used when the principal investigator has obtained a tour permit (Appendix B) through radiation safety. 

      7. Lasers

        1. The Laser Safety Officer (LSO) shall be made aware in advance of any educational demonstration, practical instruction or laboratory work involving lasers where   minors may attend or participate, except for situations involving solely Class 1 lasers which are exempt from this reporting requirement. 
        2. Minors, regardless of age or grade level, may not work with open beams produced by a Class 4 laser and may not be present in any laser-controlled areas while such work is being performed. 
        3. To perform or observe laboratory work involving Class 3B lasers, a minor shall be registered as a laser user under an approved internal laser permit and meet the following requirements: 
          1. Be aged 16 or higher, or have completed 9th grade,
          2. Be accompanied in the laser-controlled area by a qualified supervisor authorized under the approved laser permit to work with the Class 3B lasers in question, 
          3. Wear appropriate laser protective eyewear provided by the permit holder,
          4. Follow written instructions, protocols or a lesson plan reviewed by the permit holder, 
          5. Comply with laser user responsibilities as described in the ERM.EHS.RS 507 policies, and
          6. Comply with additional or alternative safety measures required by the LSO or permit holder for the planned work based on the most applicable ANSI Z136 standard(s). 
        4. When the lasers to be used are restricted to Classes 1M, 2, 2M, or visible Class 3R lasers:
          1. Simple, plain-language safety instructions explaining class-specific control measures (as required under ANSI Z136.5) shall be approved by the LSO and provided by the permit holder or the supervisor to the minors performing laboratory work or observing educational demonstrations. 
        5. All minors must have their parent or guardian sign the Parental/Guardian Consent Form/ Radiation Acknowledgement Form (Appendix A) to participate. 
        6. Additional information regarding the use of lasers by minors in teaching and research labs may be found in the ERM.EHS.RS 518 policy. 

      8. Nonhuman primates

        1. Minors aged 14-15 years old are prohibited from working with nonhuman primates.
    6.  Educational Programs which are teaching/group laboratories and not independent research are exempt from this Policy, but not other EH&S policies and requirements for handling and disposing of hazardous materials. The host school shall provide adequate adult supervision, or the Educational Program must have adequate supervision. 


Procedure

  1. Permission

    1. Official notification of each Minor participating in research laboratory activities shall be forwarded by the Faculty/Mentor to the Department Chair or higher authority such as an Associate Dean for Research. This notification form shall include:

      1. List of hazardous materials that will be used by the Minor; 

      2.  Parent/Guardian Consent Form (Appendix A) signed by parent/guardian.

        1. If the Minor is registered with an established campus program, the program coordinator is responsible for obtaining the signed forms.
        2. If the Minor is sponsored through their High School program, the Faculty Member is responsible for obtaining the signed forms. 
        3. If the Minor has contacted the Faculty/Mentor directly and is not sponsored by any program, the Faculty/Mentor is responsible for obtaining the signed forms. 
    2. The Minor must obtain an SBU ID Badge and is required to have the badge with them at all times and may be asked to wear it. 
    3. The Faculty/Mentor must notify EH&S of the lab locations where Minors will be working and the person assigned as Supervisor. 
    4. Parental/Guardian Consent Form (Appendix A) will remain in effect for one year from the date it was signed. 

  2. Training

    1. Supervisor and Faculty/Mentor must complete all required EH&S courses, including the EH&S Laboratory Supervisor Safety Training (ELS 017)-an annual requirement- prior to supervising a Minor. 
    2. Minor must complete all required EH&S training before starting work in the lab. Each laboratory presents different hazards, and therefore the required training may vary. Confirm the specific training requirements with the supervisor and contact EH&S (EHSafety@stonybrook.edu) if you have any questions. 
    3. Supervisor or Faculty/Mentor must provide the Minor with hands-on training for all laboratory procedures in which the Minor is expected to participate.  

  3. Laboratory Work

    1. Minors must have constant, direct supervision. The Supervisor must be in the lab while Minor is working. A Supervisor in an adjoining lab or office is acceptable. The Supervisor cannot be in an office that is not connected to the lab or is on a different floor. 

    2. Minors will not be allowed access to laboratories without appropriate clothing. Appropriate clothing includes long pants and closed-toe shoes. Shorts, sandals, etc., are prohibited in a laboratory.

    3. All Minors are required to wear properly fitted personal protective equipment (PPE) when working in a laboratory. The supervisor is responsible for providing appropriately sized PPE. 

    4. The Supervisor or Faculty/Mentor must have written laboratory Standard Operating Procedures (SOPs) or Protocols which include specific safety requirements available before Minor begins work. SOP templates provided by EH&S can be used. 

    5. Minors and Parent/Guardian must sign the Safety Agreement (Appendix A) that the student has received EH&S training, has access to PPE & been informed on when to wear it and understand disciplinary steps if violating PPE or supervisory rules. The signed copy must be returned to the Supervisor/Mentor before the research laboratory work can begin. 

    6. All accidents/injuries must be reported to EH&S within 5 days. The Student Accident/Injury form shall be used. A copy of this form must be submitted to EH&S. 

  4. Compliance

    1. Violations of this Policy by Faculty/Mentors or Supervisors may result in termination of Minor's authorization to work in the research laboratory or termination of Faculty/Mentor's or Supervisor's privilege to have Minors work in laboratories.
    2. Minors will be disciplined for the following: violating this Policy; violating supervision rules; failure to use appropriate Personal Protective equipment; or failure to wear appropriate clothing for laboratory work.
    3. Disciplinary actions for violation of this Policy shall depend upon the severity of the violation and can be in the form of a verbal warning, a written notice sent to the parent/guardian or expulsion/loss of lab privileges of Minor.

Definitions: 

Educational Program: organized education program sponsored by a local school/organization and approved by an SBU department. Students are accompanied by adults from the local school/organization or the Education Program provides adequate supervision. 

Minors: a person under the age of 18, participating in a program or activity that is being sponsored or operated by SBU in an SBU facility who is not enrolled in any degree granting program at SBU. 

Qualified Supervisor: an employee of SBU. The Supervisor, at a minimum, must be a graduate student working as an RA, TA or GA (or higher). This person must have received all EH&S applicable safety training. 

Research Laboratory: an area where hazardous materials, such as chemicals, biological materials and radiological materials, are used. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safely manipulated by one person. Additional hazards, such as high voltage power supplies, high power lasers and other equipment or process hazards such as burning, crushing and falling that may also be present in laboratories. It is not an instructional, computer or academic laboratory. 

Supervision: provide continual instruction and oversight of the Minor. The supervisor must be in the laboratory or an adjoining laboratory or office while the Minor is working in the research laboratory and have visual contact with the Minor. The Supervisor must determine how many minors may be in the lab at one time based on their age, the research activities involved, and the nature of the research projects. The group size must remain manageable, reasonable, and comfortable. Supervision include:

  • Educating Minors on safe laboratory techniques
  • Communicating clear safety goals and methods of achievement
  • Holding Minors accountable for all safety rules and practices
  • Completing accident reports
  • Keeping area safe from risks and hazards
  • Providing leadership and direction

 

Contact:

Additional information about this policy is available here:

Relevant Standards, Codes, Rules, Regulations, Statutes and Policies: