24.01.06.I1 Programs for Minors Rule

Approved: September 22, 2020
Revised: May 21, 2025
Next Scheduled Review: May 21, 2030

Rule Statement

The following rule outlines the requirements for programs for minors sponsored or facilitated by the Texas A&M Transportation Institute (TTI).

Reason for Rule

As required by policy of the Texas A&M University System (A&M System), reference System Regulation 24.01.06 to provide guidance to employees that may interact with non-employee minors in programs (mentoring, student volunteer) that may or may not be associated with an official high school mentor or student-learner program. This rule also provides guidance on school student field trips to TTI public offices and/or research facilities. The procedures associated with this rule, when carried out by TTI employees, will help ensure the safe and efficient accomplishment of their mentor or internship programs with minors as well as school student field trips to TTI.

For the purposes of this rule, the definition of Programs for Minors does NOT include programs:

  1. exclusively for A&M System enrolled students or employees under the age of 18.
  2. where fully supervisory duties of the minors are the responsibility of the minors’ parents, legal guardians, teachers, or official chaperones who are not member employees (examples: campus tours, school field trips, University Interscholastic League competitions).
  3. where the minors involvement is ancillary to the intended purpose of the activity.

Procedures and Responsibilities

  1. General
    1. Expectations and Guidelines for Employee and Minor Involvement
      1.   Prior to a minor being allowed to participate in a program for minors at a location owned/leased/rented or facilitated by TTI, host employees must receive approval from their department head (division head/center director), Research Group Lead, and if necessary, the Deputy Agency Director and/or Agency Director.
      2.   For purposes of this rule, a host employee must be responsible for the duties of a dedicated program director, as defined in System Regulation, 24.01.06, Programs for Minors.
      3.   All Request for Minors in the Workplace application forms must be completed, reviewed, approved, and signed by the host employee and their respective department head and submitted to TTI Human Resources for securing required background checks, confirming minor and parent/legal guardian information and signatures; then, providing final approval signature by TTI Human Resources. Information about the application process and the necessary forms can be obtained from TTI Human Resources or TTI Safety Office.
      4.   If a minor will be participating in activities in a TTI lab or shop, all requirements located in the A&M System Regulation, 24.01.08, Minors in Labs must be met by the host employee and host lab/shop manager.

        *NOTE: As per Center for Infrastructure Renewal (CIR) administration, minors, regardless of their academic affiliation, are not permitted in CIR laboratories.
      5.   Each employee working with the minor, and the minor’s parent or legal guardian, must complete the TTI Waiver of Liability and Hold Harmless Agreement (provided by TTI Human Resources).
      6.   At all times, employees must maintain professionalism and courtesy.
      7.   Established by American Camp Association guidelines, a minimum ratio of one dedicated employee to 10 program participants will be maintained.
      8.   Safety awareness information, specific to the work area, must be given to all minors. Information should include necessary safety training for the work area, emergency exits, fire alarms, restrooms, and first aid as well as areas that minors must avoid.
      9.   Written permission from the minor’s parent or legal guardian, with a copy to TTI Human Resources, must be obtained prior to the minor riding in an official vehicle (whether owned/leased/rented). Minors riding in official vehicles with employees is highly discouraged. However, if necessary to transport the minor to an agency facility or site, then two TTI employees are required to accompany the minor in a vehicle.
      10. Employees will not drink alcohol, smoke, vape, or use tobacco products when in the presence of minors and will adhere to all other TTI rules and procedures. The same applies to minors.
      11. Employees will conduct, as feasible, all involvement with minors in a public environment, being aware of all actions and statements that can be misunderstood or manipulated.
      12. As indicated in TTI’s Visitor Safety Program, prior written consent of a parent or legal guardian with a copy to TTI Human Resources is required for a minor to be allowed access to areas where hazardous materials or operations are present.
      13. Personally identifiable information regarding the minors (to include name, age, contact information, photographs, etc.), may not be shared without the minor’s parent or legal guardian’s written consent with a copy to TTI Human Resources.
    2. TTI’s Programs for Minors Rule provides guidance on, but is not limited to, the following requirements of System Regulation, 24.01.06, Programs for Minors;
      1.   Prohibition of communication, including by social media, between minors and counselors outside of official communications of the program for minors.
      2.   Retention of health information will be maintained by the TTI Human Resources office to ensure confidentiality requirements are maintained.
      3.   Risk assessment procedure to review and mitigate risks associated with the operation of the program for minors.
        1. An A&M System Risk Management and Insurance Matrix will be completed by the host employee/department.
      4.   Job description references for directors/counselors involved in the operation of the program for minors (including a minor/host employee ratio of no more than two minors to one host employee) will be included in the approval request generated by the host employee.

        A copy of the participant roster and program staff roster, including name and contact information, must be maintained for two years.
      5.   Provision for making reasonable accommodations for minors with special needs.
        1. Each program involving minors must establish a set of standards for accommodating minors with special needs. These will include, but are not limited to, the modifications of policies, practices and procedures, effective communication prior to and during the program involving minors, and the removal of physical or communication barriers to programs. Host employees must provide ample time for participants to disclose any accommodations they may need during their time with TTI. Host employees will provide TTI Human Resources information for the identification of reasonable accommodations.
      6.   Requirement for the completion of a Waiver, Indemnification and Medical Release Form for each participant.
        1. Each minor participant must complete the A&M System Waiver, Indemnification and Medical Release Form prior to their participation in activities with TTI employees.
  2. Training
    1. TTI employees participating in programs involving minors must complete the A&M System online Child Protection Training assigned by TTI Human Resources and administered through TrainTraq. Host employees must pass the course with a score of 100% every two years.
    2. Training must be completed prior to the program staff’s interactions with minors, and any new program staff hired or selected specifically for a position involving contact with minors at programs for minors must complete the training within the employees’ first five days of employment.
    3. Completion records will be maintained in the TrainTraq database and can be obtained through TTI Human Resources.
    4. Programs for minors with over 20 participants and conducted over four days must submit the Texas Department of State Health Services (DSHS)-approved training roster to the DSHS (See Appendix).
  3. Criminal Conviction and Sex Offender Background Checks
    1. Annually, both a national criminal conviction and national sex offender background check will be conducted on all program staff involved with a program for minors. The check must be performed on the program staff’s permanent address, utilizing a national criminal history database and national sex offender registration database. Documentation that a search was conducted must be maintained for a period of two years.
    2. TTI Human Resources will review and approve/disapprove program staff involvement with a program for minors based on the results of the required criminal conviction and sex offender background check.
      1.   A criminal conviction/deferred adjudication for any of the following offenses automatically disqualifies a person: Felony or misdemeanor under Texas Penal Code § 15.031 (Criminal Solicitation of a Minor); Title 5, Ch. 22 (Assaultive Offenses); Title 6, Ch. 25 (Offenses Against the Family); Title 7, Ch. 29 (Robbery); Title 8, § 38.17 (Failure to Stop or Report Aggravated Sexual Assault of a Child); Title 9, § 42.072 (Stalking) or Ch. 43 (Public Indecency); or any like offense under the law of another state or under federal law.
      2.   A criminal conviction/deferred adjudication for any of the following offenses may disqualify a person: Misdemeanor or felony committed within the past 10 years under Texas Penal Code Title 10, § 46.13 (Making a Firearm Accessible to a Child) or Ch. 49 (Intoxication and Alcoholic Beverage Offenses); Texas Health and Safety Code, Ch. 481 (Texas Controlled Substances Act); or any like offense under the law of another state or under federal law.
    3. If a national criminal conviction and/or national sex offender background check returns an offense potentially disqualifying a person, the member will refer the matter, along with its recommendation, to the Office of General Counsel (OGC) for legal review. OGC will review the recommendation for legal sufficiency and provide a written response.
    4. A copy of the participant roster and program staff roster, including name and contact information, must be maintained for two years.
  4. Neglect, Abuse, or Incident Reporting
    1. Requirement for reporting incidents or accidents involving TTI employees and minors.
      1.   A person having cause to believe that a minor’s physical or mental health or welfare has been adversely affected by abuse or neglect by any person must immediately make a report to local law enforcement. Upon notifying local law enforcement, TTI Human Resources and TTI Safety Office should be notified of the report.
      2.   Any incident involving physical injury of a TTI employee or minor, behavioral issues among employees or minors, medical facility visits or medication disbursement, must be immediately reported to TTI Human Resources following the incident.
      3.   If it is believed that a minor’s physical or mental health or welfare has been adversely affected by abuse or neglect by any person, the TTI employee must immediately notify their supervisor and Human Resources so they can make a report to local law enforcement. This legal requirement will be communicated to all employees involved in the Programs for Minors.
  5. Medication Dispensing
    1. Procedures on the distribution and security of medicine:
      1.   TTI host employees must provide and receive an Authorization for Dispensing Medication form. This form expires one year after the origin date. The minor participant’s parent or guardian may not authorize administering medication (prescription and/or over the counter) in excess of what is clearly written on the medication’s label or otherwise directed by the minor’s physician. Parent or guardian authorization is not required for administering a medication to prevent the death or serious injury of the minor, provided the medication is administered as prescribed or directed by a physician or emergency response personnel.
      2.   TTI host employees may choose not to administer any medications, but the parent or guardians must be notified prior to the commencement of the program.
      3.   Medication must only be dispensed from its original container to the minor.
      4.   Over-the-counter medication must be labeled with the minor’s name along with the Authorization for Dispensing Medication.
      5.   When a TTI host employee administers the medication, they must record the full name of the participant, name of medication, date and time the medication was given, and full name of TTI employee that administered the medication on the Authorization for Dispensing Medication.
      6.   Medication must be stored out of reach of the minor and other employees or locked away (refrigerated if required) in a way that does not contaminate food.
      7.   Unused medication will be returned to the minor’s parent/ legal guardian.
  6. Insurance
    1. Requirement to purchase general liability and accident medical coverage through the A&M System Risk Management insurance program or validation that insurance provided by third-party programs is equivalent in limits and coverage to the A&M System program.
      1.   Programs involving minor participation at locations hosted by TTI (whether at a location owned/leased/rented or facilitated by TTI, or not) may require the purchase of general liability and accident medical coverage. To determine the need and/or level of insurance required for a TTI-hosted event, program directors should contact A&M System Office of Risk Management and TTI Safety Office.
  7. Incident or Accident Reporting
    1. Requirement for reporting incidents or accidents involving TTI employees and minors.
      1.   Any incident involving minor to major physical injury of a TTI employee or minor participant, behavioral issues among employees or minors, medical facility visits or medication disbursement, must be immediately reported to TTI Human Resources following the incident.
      2.   If it is believed that a minor’s physical or mental health or welfare has been adversely affected by abuse or neglect by any person, the TTI employee must immediately notify their supervisor and Human Resources so they can make a report to local law enforcement. This legal requirement will be communicated to all employees involved in the Programs for Minors.
      3.   Any incident involving reported suspected abuse/molestation of minors must be immediately reported to TTI Human Resources or TTI Safety Office (who will then engage Human Resources).
  8. Network and Information Systems Access
    1. Provision for network and information systems access.
      1.   In order for the minor to have access to TTI network and information systems, the minor’s host employee will need to submit a ticket to request an Affiliate/Guest User Account Request to be submitted to TTI Network and Information Systems. Use of an Affiliate/Guest User account also requires that the Texas A&M University (TAMU) Information Security Awareness Training course, assigned by TTI Human Resources and administered through TrainTraq, must be completed before the account can be granted.
  9. School Student Field Trips to TTI
    1. Per instruction and agreement with A&M System Office of Risk Management, field trips are neither camps, programs, nor tours sponsored by TTI. They are school field trips to TTI public office and research buildings much like a field trip to a public park, library, etc. The participants do not have access to potentially elevated risk levels such as hazardous chemicals, substances or activities. Field trips are sponsored, facilitated and chaperoned by local schools.
    2. The sponsoring school is responsible for:
      1.   Student waiver/release forms.
      2.   Chaperones (usually teachers and parents/guardians from that school/district) that wear school/district IDs.
      3.   Maintaining headcounts of students and chaperones.
      4.   Student disciplinary actions.
      5.   Student medication dispensing.
      6.   Transportation of students, school employees and chaperones.
        1. School buses stop at the door to the building to ensure students are not crossing streets or parking lots.
        2. School buses are allowed to park in the TTI parking lots in an agreed upon location.
    3. TTI provides the following:
      1.   TTI employees as facilitators and/or speakers. They are always in the presence of school adult chaperones when minors are present. Employees are not to be alone with minors.
      2.   Chaperoned access to TTI public office and research buildings and approved areas of lab/shop buildings or research sites.
      3.   Access to parking lot at buildings.
      4.   TTI Point of Contact (POC) that helps facilitate the visit with the school/district. The POC also coordinates details such as, but not limited to:
        1. Reserves TTI rooms and advises on room configuration.
        2. Advises of bus parking location or other needs.
        3. Provides notice of visits and any related itinerary information (hours present, buildings/rooms used, etc.).
        4. Ensures building proctor has above information for building-wide email advising of school student presence on site.
  10. Additional Guidance and Reference
    1. If TTI conducts a camp or facilitates a program where TTI personnel will maintain care, custody and control of minors, the program manager and/or principal investigator will work with TAMU Division of Risk, Ethics and Compliance’s University Youth Programs to ensure participant safety and well-being.

Related Statutes, Policies, or Requirements

Appendix

Contact Office

TTI Safety Office
(979) 317-2100