Minors Participating in Research or Clinical Activities

I.  Age Restrictions

1. Persons under 12 years of age are prohibited from entering laboratories.
2. Persons aged 12-15 may not enter a Yale laboratory or participate in educational research or clinical activities, unless the activity is an approved Children and Youth program,  which may include (i) an organized laboratory tour conducted with permission of the faculty member responsible for the laboratory and the Department Chair or their designee, or (ii) a one-time educational or recruitment demonstration.  The sponsoring faculty member will be responsible for proper supervision and for providing any appropriate personal protective equipment for the visitors. Tours must be supervised at all times while on Yale premises, and tour participants may not participate in any research or clinical activities.       
3. Persons who are 16 or 17 years of age may request an opportunity to participate in approved educational research and/or clinical activities under the individual mentorship and supervision of a sponsoring faculty member, as described below¹.

II.   Requirements for Working with Minors Aged 16 or 17 in Research/Clinical Activities

1. The sponsoring faculty member must submit an application, including an appropriate supervisory plan, via EHS Integrator. Apply here: EHS Integrator
2. The sponsoring faculty member must follow all relevant safety and compliance requirements, and adhere to the supervisory plan as approved by Environmental Health and Safety (EHS). The sponsoring faculty member must also ensure compliance with university policies.
3. The sponsoring faculty member must act as the minor’s direct supervisor or designate one other faculty or staff member to serve in that role. 
4. Both the sponsoring faculty member and the designated supervisor, if any, must undergo background checks before the minor may begin the proposed research or clinical activities.  Information on this requirement can be found at https://programs-minors.yale.edu/FAQs-Labs .
5. The sponsoring faculty member and the designated supervisor, if any, must ensure that a Yale faculty or staff member or fully-trained graudate student is physically present at all times when the minor is in Yale research, clinical, or office space. Undergraduates cannot supervise minors. In addition, if the minor is working one-on-one,  with faculty or staff members who have not had background checks, the minor must be in view of a Yale faculty or staff member who has had a background check.  Finally the minor many not be present in Yale research, clinical or office space on weekends or outside the normal Monday-Friday hours of their assigned laboratory.
6. A minor must reside within daily commuting distance of Yale with their parent or legal guardian while participating in research or clinical activities at Yale.
7. Healthcare services at Yale Health or elsewhere are not provided by Yale to minors participating in clinical or research activities.  As such, minors must provide proof of medical coverage in the New Haven area for the period that they will be participating in research/clinical activities at Yale.
8. All proposed research or clinical activities conducted by minors in University locations must adhere to the requirements or restrictions imposed by the provost or provost’s designee, the department or school, Environmental Health and Safety (EHS), and where appropriate other compliance units, including the Human Research Protection Program (HRPP), Institutional Animal Care and Use Committee (IACUC), and HIPAA. Sponsoring faculty members may impose additional restrictions that they deem necessary for the safety of the minor and other members of the laboratory or work unit.
9. The sponsoring faculty member must ensure that the minor does not enter the work area prior to completing ALL required training. The minor may not participate in research or clinical activities until the minor student registration is authorized by EHS and the sponsoring faculty member is notified via email by the EHS Integrator.
10. The sponsoring faculty member must obtain an Assumption of Risk/Parental Consent form for all participants prior to allowing the minor to participate in any Yale affiliated research/clinical activities.  The sponsoring faculty member, program director or designee must ensure that these documents are uploaded into EHS Integrator.
11. The sponsoring faculty member must resolve any outstanding compliance issues, as notified via email by EHS Integrator, before the minor application is further processed.
12. The EHS Integrator will automatically generate a Create or Modify request in Sponsored Indentity once the regsitration is submitted. The sponsoring faculty member’s  department business office must approve the new minor  appointment in Sponsored Identity. Individuals approved for participation will be given a classification type of “Minor Student Research/Clinical” in the Sponsored Identity system (minors participating in research or clinical activities may not be entered into Workday). A Yale net ID will be autmatically generated, and notification sent to the minor and relevant department business office.
13. The purpose of the minor’s participation in research/clinical activities at Yale is to provide the minor with an introduction to an academic field of study and research and/or to offer the minor an educational mentoring opportunity. The research/clinical experience at Yale is solely for the educational benefit of the minor and does not constitute an employment relationship between the minor and Yale.  The minor may not receive any wages or other compensation for any of their educational activities at Yale.  A minor may receive a lump-sum stipend  to enable their participation in the activity.

    III.   Prohibited or Restricted Areas for Minors Ages 16 or 17

1. Minors ages 16 or 17 who are engaged in research or clinical activities may not work in or observe work in shops.

    IV.  ​Prohibited or Restricted Materials or Processes for Minors Ages 16 or 17

1.  Minors Aged 16 or 17 who are engaged in Research/Clinical Activities may not work with any of the following materials:

• HHS and USDA listed Select Agents and Toxins
• Human pathogens registered with the State of Connecticut DPH
• Non-human primates
• Permit required animal or plant pathogens or materials
• Toxins of biological origin with an LD50 of < 100 ug/kg body weight

• Highly toxic chemicals – LD50 < 300 mg/kg oral-rat (e.g. – Osmium Tetroxide, Acrylonitrile, Acetonitrile, Sodium Azide)
• Known carcinogenic materials (IARC Group 1 or 2) (e.g. Formaldehyde, Methylene Chloride)
• Known human reprodcutive toxins and mutagens (OSHA Category 1A or 1B) (e.g. Lead, Ethidium Bromide Powder or Solution)
• Pyrophoric materials
• Explosives and highly reactive materials
• Hydrofluoric acid
• Controlled substances     

• Radioactive Materials – Sealed and Unsealed Sources
• x-Ray Producing Equipment
• Open Beam Lasers - Class 3b or Higher

• High voltage equipment (e.g. –  Electrophoresis)
• Risk group 2 or higher shop equipment

2.  The following restricted materials require:

• a special review;
• a risk mitigation plan; and
• specific approval from the provost/designee or dean/designee as communicated by EHS, before a minor aged 16 or 17 may work with them:

• Opportunistic human pathogens that represent low risk to healthy adults
• Primary human and non-human primate cells
• Human or non-human primate blood, body fluids or tissues
• Toxins of biological origin with an LD50 of < 100 mg/kg body weight

• Suspected carcinogenic materials (as listed in the IARC Group 2B) (e.g. Chloroform, Propylene Oxide)
• Suspected human reproductive toxins and mutagens (as listed in OSHA Category 2) (e.g. Phenol)
• Concentrated acids and bases
• Large volumes of flammable liquids (>4 Liters)
• Cryogenic materials

• Magnetic Resonance Imaging (MRI)

• High pressure vessels and equipment

Last updated: May 2, 2024