Notes from the field: You don’t have staff vaccination records?

By: May 21st, 2010 Email This Post Print This Post

Recently as I was finishing a mock OSHA Inspection, I asked to see the staff vaccination records. The manager looked at me as if I had just asked the most ridiculous question. She had no idea that she was “required” by OSHA to document her employees’ hepatitis B vaccinations.

The manager stated, “I always ask everyone if they had those B shots.”

Simply asking a new employee if they have had the hepatitis B vaccine series does not comply with OSHA regulations. The new employee should present proof of vaccination.

According to the CDC, a reliable vaccination history should be a written, dated record of each dose of the complete series. For employees without proof, who claim vaccination by a previous employer, OSHA says to contact that employer and request the dated record.

Keep in mind, OSHA’s recordkeeping standard, requires employers to maintain these records for the duration of employment plus 30 years, so they should be available.

If it is not possible to obtain these records from the previous employer or the new staff member, document your efforts to obtain these records and make this statement a part of your hepatitis employee vaccination form. See the Tools page for a sample hepatitis b vaccination form.

OSHA will allow you to accept a written statement from the new employee giving the approximate vaccination dates.

You may also use the data from an “acceptable” vaccination record to continue a series that was never completed. One to two months after the third vaccination, perform testing for antibody to hepatitis B surface antigen (anti-HBs) response.

If the new employer does not administer the entire series or complete the three shot vaccination series, the new employee should NOT be routinely tested. Click here for more discussion on this matter.

In the event of an exposure the employee receives treatment as a non-responder to the vaccination in accordance with U.S.Public Health Service guidelines.


We need to be careful in the wordage used when talking about OSHA regs. 1910.1030 only says
The employer shall not make participation in a prescreening program a prerequisite for receiving hepatitis B vaccination”

We do screening of all employees as a part of their new hire process. Those with a negative titer and without prior documentation of a positive titer are offered revaccination and retesting to assure they have immunity.

Doing titers is the best way to actually know if a person is immune. That can save the person from having to get Hepatitis B Immune Globulin should they be exposed to a positive Hepatitits B patient. It also saves money in that you do not have to repeat the Hepatits B test on the employee at time of exposure if you have a positive titer on file.

It also saves a lot of time and effort in trying to find those old vaccination records. OSHA says you need to offer vaccination “unless the employee has previously received the complete hepatitis B vaccination series, antibody testing has revealed that the employee is immune, or the vaccine is contraindicated for medical reasons.”

By SUSAN WAGNER on May 25th, 2010 at 10:21 am

We have new employees and current employees with a reliable vaccination history of completion of the series in writing from years ago. It is no guarantee that there is immunity. We do screening of all employees as a part of their new hire process and have found numerous titers below the appropriate range. Many of which received vaccination greater than 10 years.

By David LaHoda on May 25th, 2010 at 11:03 am

Just FYI.

The situation you describe is addressed in the Hepatitis B and the healthcare worker, where CDC experts answer questions concerning hepatitis B vaccination. Their advice differs in how to respond to low titers years after the vaccination series as expalined inthe following Q&A:

Q: I’m a nurse who received the hepatitis B vaccine series more than 10 years ago and had a positive follow-up titer (at least 10 mIU/mL). At present, my titer is negative (less than 10 mIU/mL). What should I do now?”

A: Nothing. Data show that vaccine-induced anti-HBs levels might decline over time; however, immune memory (anamnestic anti-HBs response) remains intact indefinitely following immunization. Persons with anti-HBs concentrations that decline to less than 10 mIU/mL are still protected against HBV infection. For HCWs with normal immune status who have demonstrated adequate anti-HBs (at least 10 mIU/mL) following vaccination, booster doses of vaccine or periodic anti-HBs testing is not recommended.


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