Ask the expert: Hepatitis B vaccination and titer
Q: Is it an OSHA requirement to obtain post-vaccination titer of the hepatitis B vaccine on newly hired employees?
A: If the employer is administering the vaccine, it is a requirement as explained in the CDC’s “Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis.” That has been the case since December 1997. Here is the OSHA letter of interpretation as verification: 03/10/2000 – HBV antibody testing is required after vaccination series; HBV booster not required.
I mentioned this letter in a previous post which you may find useful: Top-ten list of OSHA interpretation letters.
If the new employee has already had the hepatitis B vaccination but records show that HBV antibody testing was not performed, then the employer is not required to obtain a titer, since a titer done more than one to two months after the last shot in the vaccination series cannot confirm immunity.
In such a situation where there is an exposure incident, you would treat the exposed employee as a non-responder to the hepatitis B vaccine, according to the USPHS Guideline.
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i would like some examples of “at risk” employees” that need to be offered the Hepatitis B vaccine. (i.e. , driver for behavioral health patients, housekeepers, maitenance, admission clerk)
Thanks
OSHA points to assessing the potential for occupational exposure more than job titles in determining which employees are covered under the bloodborne pathogens standard and therefore need to be offered the hepatitis B vaccination.
OSHA’s definition of occupational exposure is:
“Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.”
If that definition applies, no mater the job title, the worker is covered by the standard.
Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens explains the employer’s responsibility in determining whether the worker is occupationally exposed to blood borne pathogens, and offers this list of occupations that may be covered under the standard: Physicians, physician’s assistants, nurses, nurse practitioners, and other healthcare employees in clinics and physicians’ offices; employees of clinical and diagnostic laboratories; housekeepers in healthcare and other facilities; personnel in hospital laundries or commercial laundries that service healthcare or public safety institutions; tissue bank personnel; employees in blood banks and plasma centers who collect, transport, and test blood; freestanding clinic employees (e.g., hemodialysis clinics, urgent care clinics, health maintenance organization (HMO) clinics, and family planning clinics); employees in clinics in industrial, educational, and correctional facilities (e.g., those who collect blood, and clean and dress wounds); employees designated to provide emergency first aid; dentists, dental hygienists, dental assistants and dental laboratory technicians; staff of institutions for the developmentally disabled; hospice employees; home healthcare workers; staff of nursing homes and long-term care facilities; employees of funeral homes and mortuaries; HIV and HBV research laboratory and production facility workers; employees handling regulated waste; custodial workers required to clean up contaminated sharps or spills of blood or OPIM; medical equipment service and repair personnel; emergency medical technicians, paramedics, and other emergency medical service providers; fire fighters, law enforcement personnel, and correctional officers (employees in the private sector, or the Federal Government, or a state or local government in a state that has an OSHA-approved state plan); maintenance workers, such as plumbers, in healthcare facilities and employees of substance abuse clinics.
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