August is National Immunization Awareness Month (NIAM), an annual observance sponsored by the Centers for Disease Control and Prevention (CDC) that highlights the importance of immunizations. For employers with workers covered under the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard [29 CFR 1910.1030], it is also an excellent opportunity to review their organization’s Hepatitis B vaccination program and ensure ongoing compliance.
When Are Vaccinations Required?
The Bloodborne Pathogens Standard requires employers to make the Hepatitis B vaccination available to covered employees within 10 working days of initial assignment to duties involving potential occupational exposure to human blood and other potentially infectious materials.
A commonly overlooked requirement is that the vaccine must be offered only after the employee has received bloodborne pathogens training that includes information about the vaccine’s efficacy, safety, administration, and benefits. Employees must also be informed that the vaccine is provided at no cost. Because these topics are typically covered during bloodborne pathogens training, employers must ensure that it is completed within 10 working days of an employee’s initial assignment.
How Is the Vaccination Administered?
The traditional Hepatitis B vaccination schedule is a three-dose series followed by post-vaccination serologic testing (titer testing). At least four weeks must separate doses one and two, at least eight weeks is needed between doses two and three, and at least sixteen weeks is required between the first and final dose. Post-vaccination serologic testing is typically performed four to eight weeks after the final dose in the series.
Approved two-dose Hepatitis B vaccine series are also available.
What Recordkeeping Requirements Apply?
Employers must ensure that employees who do not elect to receive the vaccination sign a declination form. The agency requires specific language stating that the employee understands that by declining the vaccine, they continue to be at risk of acquiring Hepatitis B. The form must also explain that employees who initially decline the vaccine may later choose to receive it, and employers are required to make it available at no cost as long as occupational exposure continues.
Organizations often use the form not only to document declination but also to record consent to participate in the vaccination series or to request a titer to confirm immunity.
The Bloodborne Pathogens Standard includes additional recordkeeping requirements. Employers must maintain an accurate record of each employee’s Hepatitis B vaccination status, including documentation showing administration of the complete dose series. These records must be retained for the duration of employment plus 30 years. Vaccination status information can be valuable for healthcare professionals who provide counseling and treatment following an actual or potential exposure incident.
OSHA requires employers to make every reasonable effort to obtain reliable documentation of each employee’s vaccination status. This may include contacting a previous employer or the healthcare provider that administered the vaccine. If vaccination records cannot be obtained, OSHA recommends maintaining documentation of the employer’s efforts to secure them. In addition, employers should request a written statement from the employee about their vaccination status, and if available, the vaccination dates or approximate dates.
A spreadsheet or other tracking system can help employers monitor vaccine administration and titer dates, series completion status, and declinations for employees covered by the Bloodborne Pathogens Standard.
National Immunization Awareness Month is an ideal time to review your organization’s Hepatitis B vaccination program and verify that training, vaccination, and recordkeeping requirements are being met. OSHA’s Hepatitis B Vaccination Protection Fact Sheet, available in English and Spanish, provides additional guidance. For more information on OSHA compliance and best practices, contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training at Safety Partners.
