APPENDIX TO POLICY
Health and Safety Requirements and Expectations for Programs Involving Minors
Purpose: This appendix establishes minimum health and safety requirements for University of Minnesota programs serving minors under the age of 18.
Definitions: Program staff includes all individuals, paid or unpaid, who work or volunteer in a covered program and regularly interact with, supervise, chaperone or otherwise oversee minors. Please refer to the definitions attached to Administrative Policy: Safety of Minors for definitions of key words.
Program Staff Training
Program staff must receive orientation to the position, including staff/participant interactions, supervision responsibilities, ,, health and safety regulations, and emergency procedures. The document Expectations for Program Staff When Interacting with Minors is one option for conveying expectations with program staff as part of the orientation process.
In addition, it is recommended that at least one staff or volunteer at each program site receive basic pediatric and adult first aid, CPR, and AED training.
Supervisors are expected to conduct regular observations of program staff to ensure safeguards are being followed.
Supervision of Minors
Minors Attend Program without Adult
Programs that are designed for minors to attend the program without a parent, teacher or other adult caregiver are expected to provide adequate supervision of minors.
All daytime programs must have a minimum of two program staff (18 or older and two years older than the oldest participant) on duty (which means in the general vicinity and available in case of emergency); Recommended ratios are:
- For ages 8 and younger; a minimum of 1:8 program staff to youth ratio.
- For ages 9 to 14: a minimum of 1:10 program staff to youth ratio.
- For ages 15 and older: a minimum of 1:12 program staff to youth ratio.
Programs which are classroom-based may determine the appropriate ratio for ensuring a quality learning environment (1:20 is recommended).
As long as two adult program staff are on duty, the additional staff needed to meet the ratios may be youth camp counselors or teen leaders who are 16 or older and two years older than the oldest participant.
Programs that involve an overnight stay must have a minimum of two program staff (21 or older) on duty at all times regardless of the number of participants, and maintain the above ratios.
Minors Attend Program with Adult:
When University staff deliver a program off campus where minors are supervised by teachers or other adult chaperones, for example at a school or out-of-school program, the non-University program remains responsible for supervision and a teacher/group leader must remain with the minors.
Non-university schools/groups attending a University program, and adults bringing minors to a University program are responsible for their minors . The University program hosting the group may request a specific ratio to make it easier for University staff to ensure a higher quality learning experience.
Program Staff and Participant Interactions
Programs must establish and communicate expectations for program staff behavior when interacting with, supervising, chaperoning or otherwise overseeing minors in program activities, recreational activities and/or residential facilities. At minimum these standards must include:
- Program staff must avoid being alone with a minor. When one-on-one consultation is needed for discipline, mentoring or instructional purposes, the conversation should take place within view (not hearing distance) of others and another staff member should be aware that this private conversation is taking place.
- Program staff must not use physical punishment or withholding of necessities such as food, water and/or shelter to modify behavior. Physical hazing, and initiation rituals that lead to embarrassment or that require youth to do anything that makes them fearful or uncomfortable, are prohibited.
- Program staff must respect the privacy of minors when toilets are used, clothes changed, or showers taken. Program staff and participants are prohibited from the use of photography and recording devices in bathrooms or locker rooms.
- Program staff must stay with the participants, except when using bathroom or dressing room facilities. Program staff must understand procedures for conducting headcounts, making bathroom visits, and conducting room/bed checks, as applicable.
- Program staff must not engage in any behavior that is subject to mandatory reporting. Staff must maintain appropriate physical boundaries and take particular care when necessary to touch minors.
- Program staff must report any behavior that is subject to mandatory reporting to the appropriate authorities.
Programs are responsible for establishing the appropriate physical environment for planned activities to ensure quality learning environments and help prevent illnesses and accidents. At minimum, the appropriate physical environment includes:
- Safe physical space on or off campus, including indoor and outdoor space. (For use agreements, see Construction & Real Estate in the Standard Contracts Library.)
- Stations for water hydration, hand washing and first aid.
- Food service that is attentive to food allergies.
Programs must have plans in place to change facilities or modify activities for participants with special needs. (For assistance, see Disability Resource Center.)
Programs must be prepared to modify programming as needed in extreme weather, such as:
- An indoor temperature of 88 degrees Fahrenheit or higher;
- Outdoor heat index of 105 degrees Fahrenheit or higher; or
- Outdoor wind chill of 20 degrees below 0 degrees Fahrenheit or lower.
(For further information or assistance, see University Health and Safety - Occupational Health.)
Programs must assess the environment (such as the presence of minors or adults not from the same program, sight lines and distance) to determine if minors need to be accompanied to the bathrooms. Generally minors in high school do not need an adult with them.
If there is a transgender student among the participants, whenever possible use gender neutral bathrooms for the entire group so that no minor feels singled out (family or single stall bathrooms are examples.) Use the map of gender neutral bathrooms on the Twin Cities campus or this link for the Duluth campus.
Programs that lodge people overnight must establish standards to reduce the risk to minors. At minimum these standards include:
- Males must be housed separately from females, unless they are parent/child or siblings.
- Adults (program staff and program participants who are 18+) must stay in separate rooms from minors except in settings where minors and adults share a large dormitory space, or if the adult/minor is a parent/child or siblings.
- If participants represent a wide range of ages, participants should be housed with a minor(s) of similar age.
- Adults must never share beds with minors.
Programs must be prepared to accommodate minors with disabilities and transgender minors, and may consult with campus disability services and GLBT program offices for advice.
Safe Movement of Minors
Programs must have plans in place for the safe movement of minors. Situations to consider when planning include:
- Check-in and check-out procedures for safe arrival and departure of minors.
- Practices for safe movement as pedestrians and/or on campus buses, such as using a buddy system, taking head counts before and/after, and having adults at the beginning and end to ensure groups stay together while moving.
- Other methods for transporting minors, ensuring University procedures are followed for the selection of vehicles and drivers.
(For more information and resources, see University safety and security.)
Accident and Illness Prevention and Management
Programs that are designed for minors to attend the program without a parent, guardian, adult mentor, or other caretaker must collect and have at easy access information on each participant including health histories, current medications, contact information for parents/guardians and alternate emergency contacts. Program staff must know how to access this information for emergencies and non-life-threatening accidents or illnesses.
Programs must establish and communicate practices that will prevent accidents and illnesses. At minimum, these practices must address assessable and adequate first aid and proper handling and control of medications. Additional risk prevention practices are outlined throughout this document.
Program must have emergency plans in place for fire, weather (tornado), toxic gas evacuations, unfamiliar packages, intruders, lost or missing children, and other emergencies. Staff for programs located on a campus should register for TXT-U. (For further information or assistance, see Department of Emergency Management.)
Addressing Emergencies and Non-Life-Threatening Accidents or Illnesses
Programs must establish and communicate to program staff appropriate procedures for addressing emergencies and non-life-threatening accidents or illnesses. The procedures must address:
- Where to take youth in each type of emergency, how to locate emergency route signage, and how to account for everyone by taking a group head count.
- How to ensure adequate supervision of all participants while addressing an individual accident, illness, or emergency.
- Appropriate documentation of the accident, illnesses, or emergency.
- How and what to communicate with emergency personnel, parents/guardians, other program staff and participants, and media.
Waivers, Permission Forms, Medication Forms, and Other Documentation
When minors attend a program without a parent or other guardian accompanying them, programs must obtain a signed release of liability from all parents/guardians of minors prior to participation. The waiver should describe planned activities. Program leaders must contact the Office of the General Counsel to review any registration, permission, release and liability forms used in the program.
Questions on program registration can be directed to Julie Sweitzer, email@example.com.
Several University of Minnesota programs serving minors have existed for many years and have staff experienced in addressing safety and health. Policies adopted by the University of Minnesota Extension 4-H Youth Development program and University Recreation and Wellness summer day camp program provided the basis for this Appendix. Staff available for consultation with other University of Minnesota youth programs include:
- University of Minnesota Extension: Tamie Bremseth, firstname.lastname@example.org
- University Recreation and Wellness: Venessa Fiedler, email@example.com
The requirements and expectations align with the American Camp Association mandatory standards for accreditation.