The OSHA Bloodborne Pathogens Standard requires that employers make the Hepatitis B vaccination available to covered employees within 10 working days of initial assignment to duties that result in the potential for occupational exposure to human blood and other potentially infectious material.
Employers must also ensure that workers who decline the vaccination sign a declination form. Companies often use the form not only to document declination, but also to document consent to participate in the vaccination series, or to elect to have a blood titer to confirm immunity. Keeping these forms on file is required by OSHA, but the record-keeping requirements of the Standard don’t end there!
The Bloodborne Pathogens Standard has other record-keeping requirements related to Hepatitis B vaccinations that specify that an accurate copy of each employee’s Hepatitis B vaccination status, and the dates of all 3 Hepatitis B shots, must be maintained. These records must be kept for the duration of employment plus 30 years.
Per an OSHA standard interpretation letter, the reason for this requirement is that the documentation of vaccination status serves as a useful tool in assisting healthcare professionals who administer post-exposure counseling and treatment to employees following an exposure incident. Documentation showing administration of the complete 3-dose series is necessary to prevent unnecessarily repeated vaccination.
OSHA notes that employers must make every effort to obtain a reliable record of employees’ vaccination status. This may include contacting the previous employer or facility where the vaccination was administered to obtain these records. If a copy of the vaccination records cannot be obtained, then OSHA recommends that documentation verifying the employer’s attempt to obtain the records be maintained. In addition, when these records cannot be obtained from the previous employer, the current employer should obtain from the employee a written statement about their vaccination status, including the dates or, where this is not possible, the approximate dates of the vaccinations.
Using an Excel spreadsheet to track this information for each employee covered by the Bloodborne Pathogens Standard is a great way to capture not only their vaccination dates but also titer dates, vaccination declinations, and whether or not the employee has completed the vaccination series and achieved a positive titer.
For additional information on OSHA recordkeeping requirements for Hepatitis B vaccinations, or for assistance with implementing a tracking system at your facility to meet the requirements, please email firstname.lastname@example.org.
This blog was written by Beth Graham, our Associate Director of Quality, Research, and Training.