Access to Laboratories Containing Hazards

This campus policy establishes minimum acceptable criteria for allowing visitors into any campus laboratory containing hazards (see glossary below). It also clarifies the expectations and roles of principal investigators and other personnel in addressing laboratory access issues.

Special access restrictions apply to laboratories containing certain highly hazardous operations and to children (minors) and pets for a variety of reasons. Minors (persons under 18 years of age) present a special liability risk to researchers and the University, since the law assigns minors less responsibility for their actions than it assigns to adults. Furthermore, younger children, because of their underdeveloped hazard recognition skills, are at greater risk for injury from laboratory hazards.

Pets, if brought into a laboratory, could introduce additional hazards, including allergens and unpredictable behavior.

In general, campus laboratories that contain hazards have not been designed to accommodate either young children or non-research animals. 

Procedures

Laboratory visitors must be informed of the potential hazards to which they may be exposed in the laboratory, as well as of any appropriate precautions to protect themselves. This information may be provided by signage, discussion, or other means. The extent of the information provided may be tailored to the visitor’s background knowledge and previous laboratory experience.

Visitors who do not comply with established practices are prohibited from campus laboratories.

University employees who have legitimate reasons for entering a laboratory may do so provided they follow all precautions and restrictions established for the laboratory.

Minors

Minors under the age of 14 are not allowed in laboratories that contain hazards except when participating in an approved and supervised tour. In all cases, minors must be properly supervised while in laboratories.

Minors between the ages of 14 and 18 are allowed in laboratory settings only when

• They are students enrolled in courses listed in a campus course catalog or part of an approved and supervised tour, or they have written consent from their parent(s) or guardian(s); and,
• They have received the appropriate University of California safety training and the campus has documented that training; and
• They agree to strictly adhere to the campus or laboratory-specific requirements concerning Personal Protective Equipment (PPE); and,
• They are at all times under the direct supervision of a qualified adult designated for this responsibility.

Minor children of laboratory personnel are not permitted in laboratories or shops except under one of the following conditions:

• The laboratory/technical areas have been designated and posted as free of physical or chemical hazards, or
• As part of a campus/department sponsored event, or
• For the purpose of escorting a minor child to/from an enclosed office/breakroom located within a laboratory or shop.

Legal restrictions regarding certain chemicals, biological materials, and radiation may apply. Please consult the full University of California policy on Minors in Laboratories and Shops.

Pets

Pets are not allowed in laboratories. The only live vertebrate animals allowed in laboratories are those used in research, teaching, or testing and that are included on a Master Animal Use Protocol (MAUP) that has been reviewed and approved by the Animal Care & Use Committee (ACUC). Also allowed are police dogs and service animals (e.g., guide dogs) for individuals with disabilities.

Additional Restrictions for Certain Hazards and Operations

Additional access restrictions apply to some laboratories that contain the hazards listed below. For specific access rules applying to these situations, researchers must review their research authorization documents and other procedures established by the applicable research oversight committee. A link to each committee is provided below.

1. Animals to be Used in Research, Teaching, or Testing:

   1. Animal Care and Use Committee

   2. Please note that additional access restrictions for animal laboratories may be found at http://www.acuc.berkeley.edu/policies/visitors.pdf.

   3. Persons under age 18 are not permitted in University of California vivaria unless their participation has been reviewed and approved by the campus Institutional Animal Care and Use Committee (IACUC) and the responsible vivarium facility manager based upon criteria established by the campus.
2. Biohazardous (Infectious Disease) Agents:
   1. Committee on Laboratory and Environmental Biosafety
3. Biological Safety Restrictions:
   1. Minors may never work with or be present in circumstances requiring BSL-3 or BSL-4 containment. Restrictions for handling potentially biohazardous substances depend on age group:
      1. Persons ages 14 to 16 are prohibited from handling biohazardous materials that require containment above BSL-1. They may enter a BSL-1 in a large open bay laboratory where BSL-2 work may be taking place provided they have no contact with the BSL-2 work.
      2. Persons ages 16 to 18 are prohibited from handling biohazardous materials that require containment above BSL-2. They may enter a BSL-2 with appropriate training and medical surveillance (if applicable).
4. Laser Equipment or Other Non-Ionizing Radiation Sources:
   1. Non-Ionizing Radiation Safety Committee
5. Radioactive Materials or Radiation-Producing Machines:
   1. Radiation Safety Committee.

4. 1. Minors are not allowed to handle radioactive materials or radiation-producing machines. PIs must apply to their campus EH&S Radiation Safety Officer (RSO) for exceptions. Exceptions must be documented in writing. Please note that strict legal limits apply to the amount of ionizing radiation to which children may be exposed.
5. Research Involving Human Subjects:
   1. Committee for the Protection of Human Subjects
6. Select Agents:
   1. The University limits entry into laboratories that possess select biological agents and toxins (as defined by the United States Departments of Health and Human Services and Agriculture) to federally-approved personnel and individuals escorted by a federally-approved person. A list of select biological agents and toxins is available at http://www.cdc.gov/od/sap/. Researchers planning or proposing research potentially involving any of these select agents must contact the Committee on Laboratory and Environmental Biosafety at the link above at the conceptual stage of the proposed work.

Minors are never permitted in any setting where research involving controlled substances is being performed, even if they are enrolled students.

Implementation and Enforcement

Principal investigators, managers, and supervisors are responsible for implementing and enforcing this policy. Campus compliance offices and research oversight committees are authorized to audit compliance with this policy. Exceptions to this policy are allowed on a case- by-case basis only when requested in writing by the department chair or director, and approved by the Vice Chancellor-Research after consultation with the appropriate research oversight committee(s).

The restrictions listed in this policy do not apply to office spaces immediately adjacent to research laboratories. However, access through laboratory areas must be evaluated carefully against the hazards present and any procedures or restrictions established by applicable research oversight committees.

Vice Chancellor for Research:

• Approves any exception to this policy, after review and recommendation by the cognizant department chair (or director) and the appropriate research oversight committee(s).

 Office of Environment, Health & Safety:

• Assists in notifying and reminding campus researchers of this policy during laboratory safety training.
• Audits compliance with this policy during laboratory inspections.

 University of California Police Department:

• Assists researchers in enforcing this policy if unauthorized personnel should refuse to leave a laboratory.

Research Departments and Organized Research Units:

• Ensure that faculty, staff, and students are aware of this policy and adhere to its procedures.

Principal Investigators:

• Implement and enforce this policy in laboratories for which they are responsible.
• Evaluate laboratory operations for potential hazards, and establish in writing any supplemental laboratory-specific access restrictions or procedures appropriate for reasonably protecting visitors. For laboratories in which hazardous chemicals are used, such procedures should be written in the laboratory’s Chemical Hygiene Plan.
• Inform other researchers who work in the laboratory of any laboratory-specific access restrictions or procedures. In some cases, it may be useful, or even required, to post special access restrictions or procedures at laboratory entrances.