Guidelines for Minors Working or Interning in MIT’s DLCs

Guidelines for Minors Working or Interning in MIT’s DLCs

These guidelines will assist departments, laboratories or centers (DLCs) at MIT in determining how to manage the hiring or hosting of minors in a department, laboratory or center (DLC) at MIT.

MIT encourages the DLCs to provide educational programming to minors in a safe, professional and responsible manner. (See MIT's Protection of Minors site for guidance, resources, and more.)

Prior to hire or agreeing to host a minor intern or visitor, the responsible person (AO, HR Administrator, Primary Supervisor, Alternate Supervisor) should be aware that certain safety requirements and a commitment to supervise will apply, and should verify whether there are any specific approval processes required by their school or DLC. These guidelines do not apply to enrolled MIT students who are minors.

Please Note

MIT does not sponsor visas for international high school students.

Definition of a Minor

For purposes of these guidelines anyone under age 18 who is not an enrolled MIT student.

MIT Policy on the Employment of Minors (Paid)

It is Institute policy to maintain certain personnel and safety practices concerning the employment of minors. The Commonwealth of Massachusetts and the federal government place restrictions on the type of work that may be performed by minors and the hours minors may work.

MIT prohibits the employment or internships of any minors under age 16, whether paid or unpaid. Persons under 18 years of age must present certification that they are legally eligible to work. This Employment Permit is obtained through the minor’s school system. The Employment Permit must be provided to the responsible person before the minor starts work.

Learn more about the protection of minors at MIT.

Types of Minors

Paid Minors Unpaid Minors
Employee Unpaid Intern
Paid Intern Visitor

For minors who will be paid for their work, please use the following types of employment categories:

Non-MIT Student Worker (Considered "Term Employee"): Paid through MIT

MIT Term Employee applies to an employee (including minors between ages 16-18) whose appointment has specific "begin" and "end" dates. Non-MIT Student Workers can be employed on a full- or part-time basis.  If the individual is a high school or college student participating in a prescribed program of study (e.g. coop program, teen worker program, paid internship) the individual should be paid as a "Term Employee."

Please use job code HR-01ST01 Non-MIT Student Worker (non-benefits eligible).

Non-MIT Student Worker: Paid through MITemps

MITemps - Individuals who are selected by MIT managers and referred to, screened, and hired by nextSource (our designated  temporary staffing agency) for short-term assignments; i.e. those that typically have an end date, including summer employment, vacation coverage, etc. 

  1. nextSource administers and maintains all necessary personnel and payroll records. nextSource is also responsible for responding to MITemps employees’ complaints and grievances and, at the request of MIT, shall terminate any MITemps assignment at MIT. 
  2. MIT employees may not be employed by both MIT and nextSource (MITemps) at the same time.    
  3. If you hire a MITemp who is a minor, the responsible person is still required to follow all the guidelines outlined in this document (excluding MITemp minors serving as counselors for DAPER summer camp and MIT-sponsored residential summer programs).

Interns (Paid and Unpaid)

MIT prohibits interns under the age of 16, whether paid or unpaid.

On occasion, there are internship opportunities on campus for college and/or high school students through different programs such as the RSI Program, North Shore Hebrew Academy High School, and others. In addition, individuals on campus occasionally ask if a minor may intern in a DLC. 

What is an internship: An internship is a program designed to provide practical and educational experience to the participant (intern) where the intern is the primary beneficiary of his/her activities. An internship may be paid or unpaid; there are certain criteria that influence whether an internship should be paid or unpaid noted below. 

Any DLC that wants to host unpaid interns should ensure that the intern understands that he/she is offering the services freely. Unpaid interns should not displace paid workers or be used to augment staffing needs during peak periods, and unpaid interns should understand they are not entitled to wages or employee benefits for service. MIT derives no immediate advantage from the activities of the intern.

Any DLC that wants to employ a paid intern should ensure that the intern does not displace paid workers, and works under close supervision of existing staff. The intern should be paid hourly at least at minimum wage and is not entitled to a job at the conclusion of the internship.

Process for Hosting a Minor

If a DLC plans to have a minor non-MIT student worker or intern present, there are number of steps required to be taken prior to the minor’s arrival for the safety and welfare of the minor.  Minors may only be hosted or hired by MIT faculty or staff. The following steps must be taken by the responsible person:

  • Review the Checklist for hosting a Minor between ages 16 – 18 (available below) in MIT's DLCs, and complete action items required to host a minor.
  • Review supervision guidelines outlined in this document to confirm DLC supervisor will be committed to fulfilling the responsibilities required, most importantly, close supervision of the minor.
  • Create description of the activities and/or responsibilities (job description) of the minor.
  • DLC must provide their Environment, Health and Safety (EHS) Coordinator [or, if none, to EHS Office] with a description of the activities and/or responsibilities (job description) of the minor at least four weeks prior to the scheduled arrival of the minor.  The DLC or School EHS Coordinator, [or, if none, the EHS Office] will then review the description of duties and will visit the work environment to make sure it is suitable for the minor's proposed activities. Please review the following website for safety guidelines and steps required in hiring or hosting a minor: http://ehs.mit.edu/site/content/hiresponsor-minor.
  • Complete the Minor Registration Form and send it to your HRO and EHS Coordinator.
  • Complete APR hire or web based offer form for minor being paid through MIT as Non-MIT Student Worker.

Housing

Minors cannot be assigned to live in an MIT residence hall unless a parent, legal guardian, or chaperone accompanies the minor for the entire program term. Any off-campus housing arrangements required for minors are the sole responsibility of the parents. Please do not contact the MIT Off-Campus Housing Service for assistance

Safety of Minors

Principal Investigators and supervisors are responsible for the safety of the minors whom they hire/ host, just as they are responsible for the safety of their employees and students. This general guidance and the processes for minors are intended to foster a safe environment and prevent exposure to hazardous materials, lab-acquired infections, injuries, etc.  

  • The School or DLC EHS Coordinator (or, if none, the EHS Office) will provide specific guidelines on appropriate lab tasks (that comply with Child Labor Laws) for minors and will provide assistance during the Hazard Assessment process.   
  • Minors may perform certain research-related activities in a laboratory only if all of the following conditions are met:  
    • Primary/alternate supervisor and/or Administrative Officer reviewed the proposed project with the School or DLC EHS Coordinator (or, if none, the EHS Office). Please note that the Hazard Assessment process and forms must be completed prior to the arrival of the minor;
    •  Lab has addressed the applicable inspection findings;
    •  Minor has completed applicable EHS safety training; and
    •  Minor is closely supervised.  Refer to next section.

Supervision and not Working Alone

  • Minors should not, under any circumstances, work alone in the lab/shop/other work area with hazards, even if they are just using the computer.
  • The primary supervisor and/or the alternate must closely supervise the minor, i.e., work with or near him/her in the lab/shop.

Lab Attire and Personal Protective Equipment (PPE)

  • The minor should be instructed to wear closed-toed shoes and long pants to the lab/shop or change into them before entering the lab/shop.  This is especially relevant in hot weather.
  • The lab/shop is responsible for providing the appropriate PPE (safety glasses, gloves, lab coat, etc.) based on the Hazard Assessment.  Verify that the minor’s PPE fits correctly and is comfortable. The best way to ensure that the student wears PPE is by the supervisor’s example (wear it yourself) and by the enforcement of the PPE requirements with all other lab members as well.
  • The DLC is responsible for the cost of any personal protective equipment for the minor.

What to do if Accidents/Incidents Occur

  • Bring the Parental Consent/Medical & Emergency Contact Form (available below) when accompanying the minor to MIT Urgent Care or if the minor is taken by ambulance to a local hospital.
  • Call the parent/ guardian ASAP. The contact info is on the Parental Consent/Medical & Emergency Contact Form (available below). 
  • Complete the EHS Supervisor's Injury Report form.
  • Incidents not resulting in injury: If the minor was not injured but could have been injured, send a description of the incident to the School or DLC EHS Coordinator and EHS Office.
  • Incidents not witnessed or reported at the time of occurrence: If the parent reports to a supervisor that an injury did occur, then submit the Supervisor's Injury Report including the facts known and parent's account.
  • Provide assistance when an incident is investigated. 

Supervision of Minors

General Guidance for Supervising

  • Supervision is necessary for all minors. Minors should not under any circumstances be working alone in the lab/shop/other work area with hazards, even if they are just using the computer.
  • For most minors their work/internship is a learning experience and the supervisor also serves as a mentor and coach.
  • Supervisors of minors carry out important HR- and EHS-related duties and functions. 

Who Should be a Supervisor?

Faculty, Postdoctoral Associates, Researchers, Graduate Students and/or other appropriate employees of MIT may be supervisors. Minors should not be supervised by undergraduate students or non-MIT employees (e.g., contractors, staff from temporary agencies).

Supervisors should have expertise in the area in which the minor is working. 

Supervisors should be available to the minor regularly throughout the day and should address problems as they arise; therefore, before committing to supervise a minor, be realistic about your workload and other obligations. If necessary, find another appropriate supervisor.

General Supervisory Responsibilities

The primary and alternate supervisor will:

  • Work with EHS Coordinator and team to identify the hazards that need to be addressed. 
  • Provide a work area that is safe for the minor and/or that should be designated "off limits."
  • Review the final Hazard Assessment with the PI; appropriate signatures are required. 
  • Serve as a mentor/coach for the minor to ensure that the learning experience at MIT is positive/ inspiring.  
  • Keep lines of communication open, clear and constructive.
  • Supervisors should set a regular time to meet to discuss the work, provide feedback, guidance, and answer necessary questions, at least weekly. 
  • Provide a list of other department contact information for, and introduction to, key DLC contacts (e.g. the alternate supervisor, AO/Lab Manager, EHS Coordinator), especially if the minor's immediate supervisor is unavailable.
  • Ensure that the minor completes all training requirements identified during completion of the Hazard Assessment.

Training Minors

  • Minors should sign up on line for the relevant classroom courses so they can complete this training soon after they arrive. Supervisor must determine the most appropriate time for this to occur.
  • On the first day of the minor's project/program, either the supervisor or the lab's EHS Representative must give the minor the lab-/shop- specific training that is required for  all new lab members.  
  • Review the evacuation procedures for the lab and building as well as the meeting areas for good/inclement weather.
  • During this training, emphasize that:
    • Training does not empower the minor to make decisions about work with hazardous materials or equipment; their role is to follow instructions. The purpose is to educate the minor about how environment, health and safety apply to research.
    • Wherever the minor will study and work during and after his/her assignment at MIT, (s)he will be expected to follow safe work practices.
    • The minor is encouraged to ask any questions or raise concerns at any time.
    • Require the minor sign up for MIT Alert.
    • Provide an orientation to the student about the role; provide the ground rules. 
    • Provide initial and ongoing project specific training and detailed training in the skills or procedures necessary to perform required tasks for the project, and outline them clearly. Reinforce that working safely makes the results more accurate and reproducible.

Other Training and Resources

See MIT's Protection of Minors site for guidance, resources, and more.

Free Web-Based Training:

Forms Required for Minors Working, Interning or Visiting

Minors' Document retention and Distribution of forms

The AO is responsible for distributing, ensuring completion, and retaining the executed paperwork (i.e., consent/medical/release form, Hazard Assessment, if applicable).