Health and Safety Requirements and Expectations for Programs Involving Minors

Purpose: This appendix establishes minimum health and safety requirements for University of Minnesota programs primarily intended for minors under the age of 18.

Definitions: Program staff includes all individuals, paid or unpaid, who work or volunteer in a program covered by Administrative Policy: Safety of Minors and 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 are required to receive orientation and training on: 

• Staff/participant healthy interactions; 
• Supervision requirement and responsibilities;
• Quality youth programming procedure and best practices guides; 
• Health and safety regulations and protocols; and 
• Emergency preparedness.

In addition, it is recommended that: 

• At least one staff become CPR/First Aid/AED certified;
• At least one staff become Youth Mental Health First Aid certified;
• Supervisors receive Diversity, Equity, Inclusion, and Belonging training;
• Supervisors receive ADA and accessibility training; and
• Supervisors receive best practice training through the University Extension Program.

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 that 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. An agreement is recommended between the non-University program and the University program to establish clear roles and expectations.

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.

Virtual Programming

For virtual and hybrid programming, ensure that programming is accessible and safe: 

• Only utilize University of Minnesota Zoom accounts and ensure at least three participants are present; 
• Ensure all screen sharing is appropriate and only allowed for the meeting host;
• Monitor all chats; and
• Utilize the Office of Information Technology's Guide to securing Zoom meetings.

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, including in virtual settings. 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.
• Program staff must not email, text or use other social media with minors outside of necessary program communications. Program communications should include two staff members.
• Program staff are expected to use the name, gender identity and pronouns specified to them by participants, except as legally required, consistent with Administrative Policy: Equity and Access: Gender Identity, Gender Expression, Names and Pronouns.
• Program staff are expected to be mindful and understanding of the cultural, linguistic, and other forms of identity diversity of their students respecting and acknowledging different cultural practices and identities consistent with Board of Regents Policy: Diversity, Equity, Inclusion and Equal Opportunity (PDF).

Drug and Alcohol Use

Pursuant to Administrative Policy: Drug Free University, staff and volunteers may not use, possess, solicit, or sell illegal drugs, alcohol, or prescription medication without a prescription on program premises, while supervising children, or while acting on behalf of the program in any capacity.

Staff and volunteers may not consume or be under the influence of prohibited substances while working with youth, while on the program premises, or while acting on behalf of the program in any capacity. “Prohibited substances” include illegal drugs, marijuana, alcohol, or prescription drugs not taken in accordance with a prescription given to the employee or volunteer.

Staff and volunteers are prohibited from providing minors with alcohol or drugs. If a staff member or volunteer becomes aware of minors drinking or doing drugs, or being under the influence of these substances, immediately notify their supervisor.

If staff or volunteers are taking any medication (prescription or over-the-counter) that may affect their ability to safely drive or supervise youth, they must notify their supervisor as soon as possible (at a minimum before driving/supervising youth).

Physical Environment

General Facilities

Programs are responsible for establishing the appropriate physical environment for planned activities to ensure quality, accessible and inclusive 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.
• Understanding of accessible spaces and mitigation of hazards/barriers potentially faced with students of varying ability levels. In cases where students request accessibility services, please refer to the FAQ: Reasonable Accommodations for Disabilities.

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.
• Air quality index (AQI) at level orange/red (100-200 AQI).

(For further information or assistance, see Health, Safety and Risk Management – Biosafety and Occupational Health.)

Bathrooms

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.

Whenever possible use all-gender bathrooms so no minor feels singled out (family or single stall bathrooms are examples.) Use the map of all-gender bathrooms on the Twin Cities campus or All-Gender Restrooms (PDF) for the Duluth campus or Morris Campus Maps for the Morris campus.

Overnight Lodging

Programs that lodge people overnight must establish standards to reduce the risk to minors. At minimum these standards include:

• House participants with those of similar gender identities, unless they are parent/child or siblings in a room with no unrelated minors.
• 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 should be designed to be inclusive and accessible. Leaders should consult with campus disability services and LGBTQ (e.g., Gender and Sexuality Center) program offices as needed.

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.
• Program staff are prohibited from transporting youth in their personal vehicles.

(For more information and resources, see Safety on Campus.)

Accident and Illness Prevention and Management

Participant Information and Medication

Programs that are designed for minors to attend the program without a parent, guardian, adult mentor or other caretaker:

1. Must collect and have at easy access information on each participant including 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.
2. Must have program staff retain and distribute participant medications.
3. Prescription medications must be given to the program staff immediately upon arrival.
4. Medication must be in its original container, and placed in a Ziploc bag with participant’s name and instructions, including dosage amount and times.
5. Staff must keep the medicine in a secure location, and at the appropriate time for distribution must meet with the participant. The staff member must allow the participant to self-administer the appropriate dose as shown on the container.
6. Staff will log the activity in the medication.
7. Personal "epi" pens, diabetes supplies and inhalers may be carried by "any age" participant during activities. Over-the-counter medications (Advil, Tylenol, Aleve) can be held by a participant who is in 6th grade or higher.
8. Medications that cannot be self-administered should not be brought to programs.

Prevention Practices

Programs must establish and communicate practices that will prevent accidents and illnesses. At minimum, these practices must address accessible and adequate first aid and proper handling and control of medications. Additional risk prevention practices are outlined throughout this document.

Program must have written emergency preparedness plans in place for fire, weather (including tornadoes), toxic gas evacuations, unfamiliar packages, intruders, lost or missing children, active threats, self harm to themselves or others and other emergencies. These plans need to be included in staff orientation, ensuring all staff directly involved with the program know what to do in various situations. Staff for programs located on a campus are automatically registered for TXT-U. (For further information or assistance, see Department of Emergency Management.)

Programs must also identify high-risk locations and activities within their specific program and train staff to monitor and supervise these locations and activities such as:

• Locations: Isolated bathrooms, shared bathrooms, stairwells, closets, vehicles, secluded areas and showers.
• Activities: Overnight stays, unstructured time, transitions, changing clothing, transportation, field trips, bathroom breaks and mixed aged groupings.

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. It is recommended that youth participants be made aware of emergency procedures. The procedures must address:

• Where to take youth in each type of emergency, how to locate emergency route signage, how to account for everyone by taking a group head count, and how to identify a location and process for reunification between youth participants and adult caregivers in the event of an emergency.
• 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.

Minors in Research Settings

Minors volunteering in research laboratories must comply with the Department of Environmental Health and Safety requirements on Minors in the Lab. Minors should not travel out-of-state or overnight as part of University business. For example, the University unit should not fund or supervise the minor’s travel or participation in a conference. If the minor is able to travel to a conference with the financial support and supervision of an adult guardian who is not a University employee, the minor could participate in the presentation.

Minors in the Lab (UMN Chemical Hygiene Plan: 2.1 Administrative Controls)

Persons under 18 years of age are not allowed in University laboratories or other areas where hazardous materials are present or hazardous activities take place except under the following circumstances:

The minor:

1. is employed by the University or has been formally accepted as a volunteer worker; and
   1. has been trained in safe laboratory procedures; and
   2. has adult supervision at all times; – or –
2. is enrolled in a University class with a laboratory component; – or –

3. is participating in a University-sponsored program; and

   1. has been trained in safe laboratory procedures; and
   2. has adult supervision at all times; and
   3. has a Lab Use Agreement Form (DOCX) on file with the host department; 

   *If specific training modules are required for credit-bearing/enrolled students, then the training module would also be required for the minors who are participating in the lab.

   – or –

4. is visiting for academic purposes; and
   1. receives written approval from the PI/Lab Director and Department Head; and
   2. has been trained in safe laboratory procedures; and 
   3. has adult supervision at all times; and 
   4. has a Lab Use Agreement Form on file with the host department

Contact HSRM for a risk assessment if a minor needs to be present in areas where chemicals, dust, fumes, vapors, gases, biological materials, radioactive materials, or other substances present a significant hazard.

Waivers, Permission Forms, and Other Documentation

When minors attend a program without a parent or other guardian accompanying them, programs must obtain a signed (in a language or format that is accessible to the person “signing”) release of liability from all parents/guardians of minors prior to participation. The waiver should describe planned activities, date, time and location. Program leaders must use an authorized UMN form or contact the Office of the General Counsel for review of any specialized registration, permission, release and liability forms used in the program.

Retaining Youth Documents

Program leaders should follow the Records Retention Schedule for guidance indicating how long certain documents should be kept in a confidential and safe space before shredding documents.

Resources

See the Contacts and Related Information sections of Administrative Policy: Safety of Minors.