Minors as Employees or Interns

The Director of Administration of the DLC hiring or hosting the minor(s) must ensure that certain safety and other procedural steps are taken in their areas. While the Director of Administration may delegate some or all of these duties, they remain responsible for ensuring that all steps are completed.

For the purposes of these guidelines, a minor is anyone under age 18 who is not an enrolled MIT student.

Note: MIT does not sponsor visas for international high school students.

It is Institute policy to maintain certain personnel and safety practices concerning minors as employees or interns. The Commonwealth of Massachusetts and the federal government place restrictions on the type of work that may be performed by minors and the hours that minors may work.

No one under the age of 16 may be employed at the Institute in any capacity, part-time or full-time, nor may they serve as an intern or in any other unpaid capacity. Minors aged 16-17 who are employed by the Institute must present certification that they are legally eligible to work. This Employment Permit must be signed by the minor’s school.

For minors who will be paid MIT employees, please use the following types of employment categories:

Non-MIT Student Worker (Considered "Term Employee"): Paid through MIT

An MIT Term Employee applies to an employee (including minors between ages 16-17) whose appointment has specific "begin" and "end" dates. Non-MIT Student Workers can be employed on a full- or part-time basis.  If the individual is a high school or college student participating in a prescribed work-study or similar program of study (e.g. coop program, teen worker program, paid internship) the individual should be paid as a "Term Employee."

Please use job code HR-01ST01 Non-MIT Student Worker (non-benefits eligible).

Non-MIT Student Worker: Paid through MITemps

MITemps - Individuals who are selected by MIT managers and referred to, screened, and hired by nextSource (our designated temporary staffing agency) for short-term assignments; i.e. those that typically have an end date, including summer employment, vacation coverage, etc.

• nextSource administers and maintains all necessary personnel and payroll records. nextSource is also responsible for responding to MITemps employees’ complaints and grievances and, at the request of MIT, shall terminate any MITemps assignment at MIT.
• MIT employees may not be employed by both MIT and nextSource at the same time.
• If a DLC hires a MITemp who is a minor, the Director of Administration must make sure that the weekly timecard is approved and that all other guidelines outlined on this website are followed.

MIT prohibits interns under the age of 16, whether paid or unpaid.

What is an internship?

An internship is a program designed to provide a practical and educational experience to the participant (intern) where the intern is the primary beneficiary of his/her activities. MIT discourages unpaid internships unless the intern is receiving academic credit for the experience. Please review the following factors established by the Department of Labor related to unpaid internships and discuss the specific situation with your HRO and the Office of the General Counsel before determining if the internship may be unpaid.

• The intern and MIT both understand that the intern is not entitled to compensation for the time spent in the internship.
• The internship is similar to training which would be given in an educational environment.
• The internship is tied to the intern’s formal education program by integrated coursework or the receipt of academic credit.
• The internship accommodates the intern’s academic commitments and corresponds to the academic calendar.
• The internship’s duration is limited to the period of time in which the intern receives beneficial learning.
• The intern’s work complements, but does not displace, the work of paid MIT employees and provides significant educational benefits to the intern.
• The intern and MIT both understand that the intern is not entitled to a paid job at the conclusion of the internship.

Any DLC that wants to employ a paid intern should ensure that the intern does not displace paid workers and works under close supervision of existing staff. The intern must be paid hourly at least at minimum wage and is not entitled to a job at the conclusion of the internship.

For assistance in designing and implementing an internship program, please contact your HRO and the Office of the General Counsel.

If a DLC plans to host a minor as an employee or intern, there are a number of steps required prior to the minor’s arrival related to safety and welfare. Minors may only be hosted or hired by MIT faculty or staff. The following steps must be taken by the Director of Administration:

• Complete all steps identified in the appropriate Checklist for Hosting a Minor (Ages 16 – 17) in MIT's DLCs.
• Identify a Primary Supervisor and Alternate Supervisor in the DLC who will review the supervision guidelines outlined below and will be committed to fulfilling the responsibilities required.
• Create a description of the activities and/or responsibilities of the minor.

Provide your Environment, Health and Safety (EHS) Coordinator (or, if none, the EHS Office) with the job description of the minor at least four weeks prior to the scheduled arrival of the minor. The DLC or School EHS Coordinator, (or, if none, the EHS Office) will then review the description of activities/duties and will visit the work/internship environment to make sure it is suitable for the minor's proposed activities. Please review ehs.mit.edu for safety guidelines and steps required in hiring or hosting a minor.

General Guidance for Supervising Minors

Each minor must have a Primary Supervisor and Alternate Supervisor who will work closely with the minor and provide guidance and support. Supervisors must be available to the minor regularly throughout the day and are responsible for addressing problems as they arise. Supervisors are responsible for the minor regardless of the location where the minor is working or located. DLCs should ensure that individuals designated as supervisors understand these obligations and are able to include these duties in their workloads.

Supervisors must have expertise in the area in which the minor is working or located. Supervisors must ensure that minors do not, under any circumstances, work alone in a lab, machine shop, or other work area with hazards, even if they are just using a computer.

For most minors, their work or internship is a learning experience and the supervisor also serves as a mentor and coach.

Supervisors carry out important HR- and EHS-related duties and functions.

General Guidance for Supervising Minors

• Current faculty, postdoctoral associates, researchers, graduate students and/or other appropriate employees of MIT may serve as supervisors.
• Undergraduate students may not serve as supervisors.
• Non-MIT employees may not serve as supervisors. (e.g., postdoctoral fellows, independent contractors, staff from temporary agencies like MITemps)

Please review the information on the EHS website pertaining to supervision in a lab environment, lab training requirements, accident reporting, hazard assessments, and other safety guidelines. Minors may not be given keys, card access, or punch codes to laboratories, machine shops, makerspaces, or other areas with identified EHS hazards.

Supervisors and others who will work with the minor should review the training material.

Primary Supervisors and Alternate Supervisors of minors must complete a criminal background check prior to the arrival of the minors at MIT.