Seasonal intern and co-op programs are an important way to develop and integrate a pipeline of creative new talent into the life science industry. While many of Safety Partners’ clients benefit from such programs, they can also pose safety and compliance challenges. The good news is that any accommodations to the existing safety program that may be needed can be managed smoothly if properly anticipated and prepared for.
Training should always be required for anyone who will be working in labs, but training should not be approached in the usual way for summer interns and co-ops. Since they do not possess the same level of experience as the typical industry trainee, the trainer should keep in mind that certain aspects of laboratory safety and compliance will need to be explained beginning at a more basic conceptual level. Academic laboratory work may not involve all aspects of proper chemical and biological waste disposal, for example, since those functions are often not students’ responsibility. Safety Data Sheets (SDS) may also be unfamiliar. In addition, the possibility of a regulatory inspection, the success of which may hinge on their adherence to safety policies, is worth emphasizing.
Even after they are trained, interns and co-ops must be closely supervised when working in labs. Working after normal business hours is often not allowed unless direct supervision is provided. Policies and procedures for working alone or after hours may need to be tailored.
Occupational health arrangements can be more involved when there are interns and co-ops. For instance, some occupational health clinics will not treat employees if they are not covered by the company’s workers’ compensation insurance. Therefore, it’s important that efforts be made to clarify procedures and policies if a non-employee may need medical treatment, and to make sure they are understood by all parties. Even if an occupational health clinic can see and treat non-employees, notification of injuries or exposures will need to be made to the intern or co-op’s educational institution. It should be noted that OSHA injury and illness recordkeeping requirements (Forms 300, 300A, and 301) also pertain to interns and co-ops as well as a company’s own employees.
Keep in mind that certain roles and responsibilities required by regulations may only be fulfilled by a company’s own employees. Attending an Institutional Biosafety Committee (IBC) meeting, for example, can be a great way for an intern or co-op to gain experience and understanding of the research being conducted, but they may not serve as a voting member.
Additional requirements and restrictions come into play whenever minors under the age of eighteen are involved. Laws vary from state to state, but in general, minors are prohibited from working more than 40 hours per week (fewer if school is in session). In addition, they generally cannot work with radioactivity, infectious materials, or highly toxic chemicals. Minors are also often not permitted to be involved with tasks requiring the use of potentially dangerous tools such as circular saws that may be found in machine shops. In addition, certain required forms and documentation, such as hepatitis B vaccination declinations, may need to be signed by a parent or guardian.
As the departure date nears for the temporary population of interns or coops, a survey of their work areas is advisable to check container labeling, waste collection methods, and any other areas where missing or incomplete information may be difficult to obtain once the users have left. It can also be helpful to solicit feedback on training and other elements of the safety program, so that adjustments can be made to help it run even more smoothly and effectively for the next group.
For additional information, or for help ensuring a safe and compliant intern and co-op program at your organization, please contact us.
This blog was written by Chris Neal, a Quality, Research, and Training Specialist at Safety Partners.