Providing Safe Environments for Participating Minors

The wide variety of activities offered by our colleges and universities comes with many forms of risks. The policies we write and facilitate are designed to help educate our communities and reduce the risks to our institutions and community members.

Many colleges and universities operate programs and/or activities that involve the participation of minors. Providing a safe environment for participating minors is important for compliance with legal and risk management requirements.
My institution, Washington State University (WSU), published a new executive policy (EP14) in September 2023 that sets forth best practices and requirements to address the special health, safety, and security risks associated with activities involving minors. I wanted to share some of our policy choices for your consideration.

Factors WSU Included in Our Policy

Applicability -- We thought it advisable to clearly outline both what/who the policy applies to and what/who the policy does not apply to, in order to limit confusion and questions.

Definitions -- We included definitions of applicable terms used throughout the policy including, but not limited to:

• Abuse or neglect of minors; 
• Adequate supervision; 
• Authorized adult or program staff; and 
• Bullying.
  

Roles and Responsibilities -- We included:

• Roles and responsibilities for the program and authorized adults;
• Responsibilities of non-university organizations and entities; 
• Rights and responsibilities of minors, including: 
• Immunization requirements, 
• Disability accommodations, and 
• Prohibited actions.
  

Requirements -- We included requirements regarding:

• Program registration;
  
• Participant registration;
  
• Authorized and program staff training and conduct;
  
• Screening and background checks;
  
• Adequate supervision of minors;
  
• Overnight campus activities involving minors; 
  
• Transportation involving minors;
  
• Education for minor visitors and their parents;
  
• Reasonable accommodations and medication management; 
  
• Specific requirements for minors participating in higher risk activities; 
  
• Reporting; and 
  
• Addressing reports of abuse or neglect.

References and Resources -- Our administration asked us to provide links to reporting forms and templates provided through our Compliance and Risk Management office, as well as links to other existing WSU policies regarding minor dependent children and minor volunteers.

Responsible Offices and Enforcement -- As you are all likely very aware, easy access to the offices to contact for concerns and assistance is a key factor in user compliance with any policy. And as with any policy, affirming regular review of the policy and providing a description of what administrative bodies or personnel are responsible is also important for risk reduction.

Additional Requirements for Minors Involved in Research Activities

In keeping with the missions of education and outreach at research colleges and universities, persons under 18 years of age may occasionally be allowed to enter research or teaching laboratories for educational or research purposes.

However, there are strict federal and state limits on the amounts and types of chemical, biological, and radioactive substances that minors may be exposed to. As WSU is a research university with schools of medicine and global animal health, a nuclear reactor, and a wide variety of other research activities, we added a supplemental appendix to EP14 to outline the applicable regulations and requirements applicable to minors in our laboratories.

Your Policy on Protecting Minors

In today's litigious environment, we policy administrators help to protect our institutions by advising on and facilitating the development of policies to help reduce the many risks that may arise. I hope what I've shared from the WSU perspective helps you start or continue your own conversations about developing or revising a policy for protecting minors who may participate in activities and programs at your institution.

Articles on topics that may affect your organization’s policies

As we continue the fall semester, the Blog Committee would like to share some of the articles we’ve been reading that relate to policy administration in higher education.

• Class Notes: The gender poverty gap, COVID-19’s impact on college students, and more
  By Ember Smith and Richard V. Reeves, The Brookings Institution, Sept. 9, 2020
• A Perception Problem About Free Speech
  By Greta Anderson, Inside Higher Ed, Sept. 29, 2020
• University of California must stop all use of SAT and ACT in admissions, judge orders
  By Michael Burke, Ed Source, Sept. 1, 2020
• Accommodations in the Time of COVID
  By Nancy Gunzenhauser Popper, Talent Management and HR, Aug. 31, 2020
• UW System: Registration is now open for national public summit on preventing sexual harassment in higher education
  WisBusiness.com, Sept. 29, 2020
• 4 COVID-era Cybersecurity Threats CISOs are Confronting
  By Matt Zalaznick, University Business, Aug. 20, 2020
• California Bill Likely Conflicts with New Title IX Regulation
  By Jeremy Bauer-Wolf, Education Dive, Aug. 28, 2020