The School of Medicine (SoM) views the opportunity to volunteer in a laboratory as a very important educational experience, introducing volunteers to the workings of a research laboratory and often helping them to explore possible future career choices. The SoM encourages faculty to provide such opportunities to individuals seeking a lab experience and welcomes those who meet the requirements of the SoM Lab Volunteer Policy.

A) Purpose

The SoM lab Volunteer Policy clarifies who is authorized to .volunteer in SoM labs and outlines procedures for departments to screen and engage lab volunteers. This Policy collects requirements from Federal and State regulations and UW policies that apply to lab Volunteers. SoM departments that engage lab volunteers must follow this Policy.

B) Definition of Volunteer

Volunteers may serve in SoM labs with departmental supervision and under the following circumstances that define a "volunteer" under state and federal law:

• Volunteer service is unpaid, with no coercion or pressure to serve

• Volunteers should have no expectation of receiving pay or other tangible benefits including future positions at the University

• Volunteers may be reimbursed for actual expenses necessarily incurred in performing assigned or authorized duties, but may not receive additional compensation including a stipend

• Volunteer service does not displace a current or previous paid position and is not substantially the same as a paid position

• A volunteer does not currently and did not previously hold paid employment performing the same tasks

See WA Dept of Labor and Industries Employment Standards Administrative Policy ES.A.1 defining volunteer

C) Policy

• Volunteer service in SoM labs should not displace work performed by University employees or be used to circumvent the established processes that govern University hiring

• ScM lab volunteers are not employees of the University and their volunteer service is not covered by the Fair Labor Standards Act (FLSA) or Washington wage and hour laws

• SoM lab volunteers are covered by the University's workers compensation insurance policy and anyone who supervises SoM lab volunteers is required to track the dates and hours of volunteer service to insure coverage

• Volunteer status may not be used as a way to avoid or defer compliance with the employment eligibility requirements of federal immigration laws, including allowing an individual to volunteer in situations where they are not authorized to work

• Departments may not engage an individual for volunteer service if he or she was terminated from University employment, resigned in lieu of termination or separated from University employment under an agreement or circumstances that prohibit future employment at the University

• Departments are discouraged from allowing volunteers to work with hazardous substances, biohazards, radiation or tools and may allow such work only if the volunteer takes appropriate training

• Minors may not work with biohazardous materials (including human body fluids, human cell and cell lines), radioactive and hazardous chemicals or substances, hazardous equipment (including power-driven machinery) and jobs requiring personal protective equipment other than gloves, boots, eye protection, or hard hats

D) Applicability

1) The following individuals may volunteer in SoM labs:

• Individuals who are 18 years or older and meet the above criteria for volunteer service
  
  

• Minors may volunteer with limited hours, restricted activities, and with a parent/guardian signature on the Volunteer Service Agreement acknowledging the risks of volunteering in a lab and consenting to medical treatment in case of an injury or accident. Additional Information for Minors may be found on the Labor & Industries web page.
  
  

• UW or other university students who are not seeking academic credit for volunteer service; students seeking academic credit should explore an internship

• UW employees whose job duties are substantially different from the volunteer service

• Individuals with visa status that authorizes work may volunteer, including:

• Students with an F-1 visa that authorizes work at the UW or students with an Employment Authorization Document ("work permit")

• Individuals with J-2 visas, green card applicants, asylum seekers and refugees may volunteer with an Employment Authorization Document ("work permit")

Note: Federal immigration authorities interpret volunteer service as employment. An individual without unrestricted work authorization who volunteers in a position that is not a traditional volunteer position (e.g., traditional hospital candy striper), may jeopardize his/her visa status and subject the University to significant fines and potential loss of federal research funds. Departments should consult with the International Scholars Office ("ISO") or the Dean's Office before allowing individuals with visas to serve as volunteers.

2) The following individuals may NOT volunteer in SoM labs:

• Any individual whose visa status does not authorize unrestricted "work" in the U.S., which may be interpreted to include volunteer service under immigration law, including:

• Individuals with H4, F-2 or TD visas

• Individuals with pending H1-B or other visa applications to work at the University must consult with the Dean's Office to determine whether their current status allows volunteer service

• Volunteer service for use as a trial period intended to lead to paid employment is prohibited

E) Department Responsibilities

1) Before the volunteer service begins

• The PI should assign an individual to serve as the volunteer's supervisor to ensure the volunteer has the appropriate supervision, experience, qualifications, and training for the lab tasks the volunteer will perform

• The PI or departmental employee designated by the PI must be present to supervise the volunteer in the lab/work space. With prior approval from the departmental chair, this may be waived for volunteers with significant experience or ability

• The supervisor must ensure the volunteer reads the SOM Lab Volunteer Policy, completes the SOM Volunteer Service Agreement, and provides the form to the department director or administrator to sign and maintain

• Departments must contact their employment specialist in UW HR to conduct a criminal background check if a volunteer will have access to personally identifiable information about students, faculty, staff, alumni, donors or research subjects; direct access to pharmaceuticals or controlled substances; or will have regularly scheduled unsupervised access to children under age sixteen, developmentally disabled persons, or vulnerable adults

2) Training requirements

Environmental Health & Safety requires that lab volunteers receive the same level of protection as employees, including personal protective equipment training. At a minimum, the supervisor must provide the following safety orientation for lab volunteers:

• Asbestos Awareness Training

• Emergency evacuation procedures and routes

• Hazardous awareness training for hazardous chemical, biological and radiological agents in the work area and UW procedures for first aid and medical follow-up in case of exposure to hazardous material

• Additional training may be required based upon the volunteer's activities and potential lab hazards

• Volunteers who work with chemicals, blood/body fluids, radioactive materials, or animals must complete specialized EH&S training

• Volunteers who work directly with animals, unfixed animal tissues, or body fluids, or whose activities are in animal housing areas must undergo Occupational Health and Safety Program Animal Use Screening  prior to volunteer service.

3) Required lab volunteer documentation

Departments must maintain documentation of the following information for lab volunteers:

• Dates and hours of the actual volunteer service. This information establishes eligibility for the University's workers compensation insurance policy which pays medical expenses if a volunteer is injured. Volunteers follow the same claim filing and accident reporting procedure as employees.  

• Documentation, such as placing the completion certificate or note in the volunteer's file, to reflect that the volunteer has taken adequate safety and workplace training including:

• Appropriate lab safety orientation and training as detailed in the Training Section

• HIPAA Compliance training, if applicable

• Copies of the following documents, signed by the volunteer:

• SOM Volunteer Service Agreement

• UW Medicine Privacy, Confidentiality, and Information Security Agreement

• Documentation that the supervisor has reviewed the following information (available on-line) with the lab volunteer:

• HIPAA Compliance Information Sheet (if applicable)

• UW Policy on Personal Use of University Facilities, Computers, and Equipment by University Employees

The primary purpose of the training listed above is to ensure volunteers' safety in SoM labs. PIs and volunteer supervisors should also adequately screen and train lab volunteers to protect research experiments, to protect lab equipment, and to safeguard proprietary information.

F) Lab Volunteer Responsibilities

• Volunteers must complete the Lab Volunteer Service Agreement (link to the pdf service agreement) to acknowledge their understanding that volunteer service is unpaid and will not result in a future paid position or any other tangible benefit

• For minors, a parent/guardian must acknowledge the risks of the volunteer service and consent to medical treatment in case of an injury or accident

• Volunteers must read and comply with this policy and all University, SOM, and departmental policies required by the lab PI or departmental volunteer supervisor

Policy approved by:
Mark S. Green
Associate Dean for Business
Dean's Office, School of Medicine
SoM Laboratory Volunteer Policy
May 11, 2011

Additional EH&S Laboratory Health and Safety Resources

For more information on health and safety in laboratories consult the following EH&S resources:

• UW Laboratory Employee Safety Training Checklist
• Training courses registration
• UW Laboratory Safety Manual
• EH&S Laboratory safety webpage