There are a couple of issues here. Students are not employees unless they are being paid to do a job, so OSHA rules don’t apply in this instance. Since you have referenced undergraduate research students, it would not appear they are “employees”.
That said, it should be up to the PI to make sure the student is appropriately trained and does only what is approved. Otherwise the school and the PI could have civil or even criminal liability (see Harran, Patrick).
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
610-322-0657
rphifer**At_Symbol_Here**wcenvironmental.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Tammy M. Lutz-Rechtin
Sent: Tuesday, July 5, 2022 2:09 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Question regarding undergraduate research without the PI on site
I am uncertain as to “regulations for undergraduates.” If they are over 18, they are adults subject to the same regulations as us. Ultimately, this is a liability issue. However, my university as safety policy does require a “buddy system” for undergraduates during working hours, supervision after-hours, or a “work alone” form. The “work alone” document establishes hours for working, communication requirements, and limits on the type of activities allowed. For example, a student with PI approval may work on Saturdays between 9 am-5 pm if the PI is contacted by text when entering & leaving and only does activities outlined and considered low-risk by the PI.
Tammy Lutz-Rechtin
Dear Reader,
I am Jonathan Dannatt. I am a fairly new assistant professor at a primarily undergraduate institution, University of Dallas and was hoping you could guide me and our department a bit.
We are currently re-writing our chemical hygiene plan and came across a dilemma. We are unsure if there are laws or ACS guidance surrounding undergraduate research students to perform simple, PI approved tasks in the lab while the PI is not present. For example, if on a Saturday a water bath needs to be filled or a reflux needs to be stopped, are there laws or safety regulations prohibiting a pair of students coming into the lab and completing this task? Is there any specific ACS guidance in this area?
Again thank you for any advice or assistance you can provide.
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