- OSHA Healthcare Advisor - http://blogs.hcpro.com/osha -

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

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 [1].

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 [2]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 [3].