Working Alone at MIT
Many of us remember a tragic accident at Yale university a little more than two years ago resulting in the death of an undergraduate student working alone late at night. When accidents happen, the entire college and university sector cooperates on learning and applying lessons from such incidents. After this tragedy, many groups here, led by the MIT EHS (Environment, Health, and Safety) Office, examined our working-alone practices and have modified and coalesced various policies around the Institute.
A comprehensive Working Alone Policy for the Institute was adopted by Academic Council last year. This Working Alone Policy and Guiding Principles applies to all departments, labs, and centers where research and teaching involves working with hazardous materials, equipment or operations that may create the risk of injury. The goal of the policy is for all parties to carefully evaluate the hazards present prior to working alone; and decide that in some cases people should not work alone.
Similar policies have been adopted by various Institute oversight committees over the years. Some committees had explicit policies that did not allow undergraduates to work in a research laboratory without supervision, while others had no policy, or an informal one. This policy unifies our local practices.
The intent of the Institute policy is to have the Principle Investigator (PI) or supervisor and anyone working with or who intends to work in potentially hazardous conditions that could result in serious injury or immediate harm make a careful assessment of the activities prior to working alone. Several regulatory enforcement and court cases indicate that PIs have supervisory responsibility for the safety of personnel working in his or her laboratory. It is recognized that nearly all activities in a laboratory could, if not closely managed by all involved, result in serious injury. The assessment will determine whether the risk of working alone is controllable under specific conditions established by the PI or supervisor. If the risk cannot be minimized to a controllable level, as determined by the PI or supervisor, then the individual should perform the work only when others are present or a suitable alarm device is available that will summon help immediately. The PI or supervisor must determine hazardous conditions that can result in immediate injury or death with assistance from their department, laboratory, or center EHS coordinator or the EHS Office on a case-by-case basis.
The objective of the policy is to provide clarity and consistency around this issue without hindering research, and to promote the development and adoption of a routine assessment process to determine whether any given operation should be allowed to be performed alone. It is intended to mitigate those incidents or accidents where there is an immediate need for assistance to provide help and/or call for help (e.g., emergency responders).
The new policy is consistent with existing ones in MIT Human Resources for employees, the Committee on Assessment of Biohazards, Radiation Protection Committee, Committee on Toxic Chemicals, and Division of Comparative Medicine regarding supervision of undergraduates in research laboratories and animal facilities. The policy states the minimum requirements for working alone across the Institute, although any specific working-alone policies from Institute Committees or individual DLCs or individual PIs or supervisors that are more restrictive shall take precedence. It would not apply to areas outside laboratories such as offices or classrooms, where hazardous materials, equipment, or operations would not be expected to be present.
Working alone applies to all employees, faculty, students, and staff, anytime, night or day, when no one else is in direct line of sight or within sound of the person.
Devices that can be worn to sound an immediate alert to a central, continuously manned location (e.g., Police, Facilities) may be substituted for people in some situations. The use of a cell phone as an emergency contact device may also be adequate in certain situations.
Additional measures apply to undergraduates. Undergraduates shall not work alone with hazardous materials, equipment, or operations that can result in immediate injury or death without prior written approval from the immediate PI or supervisor. Written approval should only be granted after the risk assessment is performed, documented, and reviewed by the PI or supervisor with the individual. Once this review is done it does not need to be repeated for subsequent similar activities. A system will be established and maintained by the EHS Office to compile individual conditions, which a PI or supervisor can refer to for guidance. In some cases the approvals will be associated with a research registration or authorization. The EHS Office will serve to provide consistency across our campus.
This policy is linked from MIT’s Policies & Procedures, Section 9.2.2 and the Human Resources Personnel Policy Manual, Sections 3.1.1 and 5.4.1. DLC-EHS staff and the EHS Office will assist in the implementation of the policy. For more information contact the EHS Office at email@example.com.