Volunteers and Minors in Animal Research Facilities (ABSL-1 and ABSL-2) and at Field Research Sites
Number: IACUC-POL-017
Responsible Office: Office of Research and Creative Scholarship (ORCS)
Applies to: All volunteers and individuals under 18 years of age participating in or entering animal research facilities, laboratories, or field research environments involving live vertebrate animals or hazardous materials.
Purpose
The purpose of this policy is to establish clear requirements and institutional expectations regarding the participation of volunteers, minors, and volunteer minors in research environments at the University of Montana. This policy ensures compliance with federal regulations, protects participant safety, maintains animal welfare standards, and preserves the integrity of research activities.
This guidance applies to all spaces and field sites where live vertebrate animals are housed or used, where hazardous materials, equipment or hazardous situations are present.
Background
Federal and institutional regulations—including OSHA, the Animal Welfare Act, the Guide for the Care and Use of Laboratory Animals, and university EHS requirements—impose strict standards for individuals entering research or animal use areas.
Volunteers and minors are not considered trained laboratory personnel and require additional safeguards, supervision, and institutional oversight. Participation is limited to pre-approved, low-risk activities with appropriate documentation and risk mitigation measures in place.
Definitions
- Minor: Any individual under 18 years of age, including enrolled university students
- Volunteer: An individual providing services without compensation who is not an employee or student acting within a paid or academic role
- Volunteer Minor: A minor formally registered as a University volunteer
- Animal Facility/Field Site: Any space where live vertebrate animals are housed or used for research, teaching, or testing
- ABSL-1: Low-risk animal research involving agents not known to cause disease in healthy adults
- ABSL-2: Moderate-risk animal research involving agents associated with human disease
Policy Requirements
VOLUNTEERS
General Requirements for Volunteers:
- All volunteers must complete the UM “Agreement for Non-reimbursed Volunteer Services” form and submit it to the Office of Risk Management when completed. For volunteers who are minors the form must be signed by a legal guardian.
- For volunteers participating in animal studies that involve hands-on work. They must be listed as approved personnel on the protocol and complete the following:
- IACUC specific training
- UM Occupational Health and Safety Requirements
- Acknowledgement of Risk Form through the office of Risk Management.
- Volunteers participating in field research and field studies are required to follow PI directions and guidance; and complete additional training if the PI deems necessary.
- Emergency contact information must be available on site, and all participation must comply with institutional policies and approved research protocols.
Volunteer Restrictions
- Volunteers are not covered under the University workers’ compensation
- Volunteers (including minors) are not permitted to operate University-owned or rented vehicles
MINORS
All individuals supervising minors in any setting must, unless they are the minor’s legal guardian read and adhere to UM policy #1023, “Minors on Campus.”
General Restrictions for Animal Facilities:
Children 14 years of age and under are prohibited from all animal facilities unless in the presence of legal guardian.
Minors (ages 15–17):
- Must be in the presence of an authorized adult and
- May not work with or handle:
- Live vertebrate animals
- Animal tissues, carcasses, primary cells (ABSL-1 only), or fluids
- Hazardous chemicals, biological agents, or radioactive materials
- Laboratory equipment with mechanical, electrical, or thermal hazards
Requirements for Animal Facilities
Minors may be present for the purpose of:
- Structured educational programs
- Job-shadowing or observation
- Pre-approved STEM enrichment activities
Due to animal welfare and biosafety considerations:
- Minors are only permitted in animal facilities for pre-approved observation activities
- Minors may not disturb, handle, or feed animals
- Access is limited to non-procedural, ABSL-1 areas
- Entry must not disrupt ongoing research or animal husbandry operations
- Continuous, direct supervision is required
Prohibited Activities
Minors are not permitted to:
- Conduct any animal procedures (handling, injections, necropsy, surgery)
- Enter vivarium or USDA-regulated animal spaces without prior approval
- Work with BSL-2 or higher biological agents
- Work with controlled substances
- Handle sharps or surgical instruments
General Restrictions for Field Studies and Field Research
Common participation scenarios include:
- Sponsored educational and outreach programs (e.g., NSF K–12 or similar funding programs).
- School‑based projects, where local high school students work with UM faculty or graduate students on approved field research activities (e.g., camera trapping or observational data collection).
All minors must be directly supervised at all times by approved project personnel and may not work independently. Activities must be age‑appropriate, non‑hazardous, and assistive or observational and at the discretion of the PI.
References
- Guide for the Care and Use of Laboratory Animals
- Animal Welfare Act Regulations (9 CFR)
- OSHA Laboratory Standard (29 CFR 1910.1450)
- Biosafety in Microbiological and Biomedical Laboratories (BMBL), 6th Edition
- University of Montana EHS Laboratory Safety Manual
- University of Montana Policy 1023 – Minors on Campus
- Occupational Health and Safety in the Care and Use of Research Animals
Review, Approval and Version History
|
Version |
Date |
Description of Changes |
Approved By |
|---|---|---|---|
|
1.0 |
May 12, 2026 |
Initial Creation |
IACUC Committee |