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Is Your Hepatitis B Vaccination Program Fully Compliant?

August is National Immunization Awareness Month (NIAM), an annual event sponsored by the CDC to highlight the importance of immunizations. What better time to review your company’s Hepatitis B vaccination program to ensure that it’s fully compliant!

The OSHA Bloodborne Pathogens Standard requires 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.  However,  is not sufficient to simply offer the vaccination and take no further action!

What can be overlooked is that the vaccination is required to be offered after the employee has received training that includes information about the vaccine and vaccination, including its efficacy, safety, method of administration, and the benefits of vaccination. They must also be informed that the vaccine is offered at no cost to the employee. This training is generally included as part of overall bloodborne pathogens training which means that bloodborne pathogens training also needs to take place within 10 days of  initial assignment/hire!

Employers must also ensure that workers who decline the vaccination sign a declination form. There is required language that must be included in the form that states that the employee understands that by declining the vaccine, they continue to be at risk of acquiring Hepatitis B. It also explains that if an employee initially declines to receive the vaccine, but at a later date decides to accept it, the employer is required to make it available, at no cost, provided the worker is still occupationally exposed. 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 titer to confirm immunity.

For employees who elect to participate in the vaccination program, the vaccine is a series of three doses followed by an immunity (titer) test.  There must be at least 4 weeks between doses #1 and #2, at least 8 weeks between doses #2 and #3, and at least 16 weeks between doses #1 and #3. The titer is usually drawn 4-8 weeks after shot #3.

It’s important to note that the Bloodborne Pathogens Standard has specific record keeping requirements related to Hepatitis B vaccinations including maintaining an accurate copy of each employee’s Hepatitis B vaccination status and the dates of all Hepatitis B shots.  Using an Excel spreadsheet to track this information for each employee covered by the 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 requirements for Hepatitis B vaccinations and tips for ensuring ongoing compliance, please email [email protected].

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