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FAQ - Regulatory Processes - 2016
FAQ - Regulatory Processes - 2016

 

 

Post vaccination screening for Hep B is conducted 1-2 months after the 3 dose series is completed. Is the employer/Dr. responsible for paying for this? 


Ask OSAP would like to reference
Infection Control and Management of Hazardous Materials for the Dental Team which states as follows:

The availability of safe and effective vaccines for hepatitis B is fortunate. Because no successful medical treatment exists to cure this disease, prevention is of paramount importance. Chapter 9 presents details on the vaccines and the vaccination series. The vaccines are strongly recommended for all members of the dental team. The Occupational Safety and Health Administration of the U.S. Department of Labor actually requires dentist-employers to offer the hepatitis vaccine series free of charge to office staff who may have any potential for exposure to blood or saliva. The requirement applies to employees in all health care and other professions in which body fluid exposure is possible. 1

OSHA’s Bloodborne Pathogen’s standard states:

1910.1030(f)(1)(i)

The employer shall make available the hepatitis B vaccine and vaccination series to all employees who have occupational exposure, and post-exposure evaluation and follow-up to all employees who have had an exposure incident.

1910.1030(f)(1)(ii)

The employer shall ensure that all medical evaluations and procedures including the hepatitis B vaccine and vaccination series and post-exposure evaluation and follow-up, including prophylaxis, are:

1910.1030(f)(1)(ii)(A)

Made available at no cost to the employee;

1910.1030(f)(1)(ii)(B)

Made available to the employee at a reasonable time and place;

1910.1030(f)(1)(ii)(C)

Performed by or under the supervision of a licensed physician or by or under the supervision of another licensed healthcare professional; and

1910.1030(f)(1)(ii)(D)

Provided according to recommendations of the U.S. Public Health Service current at the time these evaluations and procedures take place, except as specified by this paragraph (f). 2

OSHA also states the following on its website:

HBV Vaccination

The standard requires employers to offer the vaccination series to all workers who have occupational exposure. Examples of workers who may have occupational exposure include, but are not limited to, healthcare workers, emergency responders, morticians, first-aid personnel, correctional officers and laundry workers in hospitals and commercial laundries that service healthcare or public safety institutions. The vaccine and vaccination must be offered at no cost to the worker and at a reasonable time and place. 3

Immunization of Health-Care Personnel: Recommendations of the Advisory Committee on Immunization Practices (ACIP) states as follows:

Preexposure

Unvaccinated and Incompletely Vaccinated HCP and Trainees: Pre- and Postvaccination Serologic Testing

·        Prevaccination serologic testing for previous infection is not indicated for the majority of persons being vaccinated because of occupational risk unless the hospital or health-care organization considers such testing cost-effective (3,52,69--72). However, such testing is indicated for HCP and is cost-effective in certain high-risk populations (see HCP and Trainees at Additional Risk), regardless of vaccination status (71,73).

·        All unvaccinated persons whose work- and training-related activities involve reasonably anticipated risk for exposure to blood or other infectious body fluids (e.g., HCP, long-term--care facility staff, and public safety workers) should be vaccinated with the complete, ≥3-dose hepatitis B vaccine series.

·        Persons with an incomplete series are not considered protected and should complete the ≥3-dose series.

·        Because higher risk has been reported during the professional training period, the vaccination series should be completed before trainees have contact with blood; vaccination should be offered in schools of medicine, dentistry, nursing, laboratory technology, and other allied health professions.

·        To determine the need for revaccination and to guide postexposure prophylaxis, postvaccination serologic testing should be performed for all HCP at high risk for occupational percutaneous or mucosal exposure to blood or body fluids. Postvaccination serologic testing is performed 1--2 months after administration of the last dose of the vaccine series using a method that allows detection of the protective concentration of anti-HBs (≥10 mIU/mL). Persons determined to have anti-HBs concentrations of ≥10 mIU/mL after receipt of the primary vaccine series are considered immune, and the result should be documented. Immunocompetent persons have long-term protection and do not need further periodic testing to assess anti-HBs levels. Postvaccination testing for persons at low risk for mucosal or percutaneous exposure to blood or body fluids (e.g., public safety workers and HCP without direct patient contact) likely is not cost effective (52); however, persons who do not undergo postvaccination testing should be counseled to seek immediate testing if exposed.

·        Persons determined to have anti-HBs concentrations of <10 mIU/mL soon after receipt of the primary vaccine series should be revaccinated. For these persons, administration of a second complete 3-dose series on an appropriate schedule, followed by anti-HBs testing 1--2 months after the third dose, usually is more practical than conducting serologic testing after each additional dose of vaccine.

·        Persons who do not have a protective concentration of anti-HBs (≥10 mIU/mL) after revaccination (i.e., after receiving a total of 6 doses) should be tested for HBsAg and anti-HBc to determine infection status. Those determined not to be infected but who have anti-HBs <10 mIU/mL (nonresponders) should be considered susceptible to HBV infection and should be counseled about precautions to prevent HBV infection and the need to obtain hepatitis B immune globulin (HBIG) postexposure prophylaxis for any known or likely exposure to HBsAg-positive blood (72). Persons determined to be infected (anti-HBc-positive) and positive for HBsAg should be provided counseling regarding how to prevent HBV transmission to others and referred for further evaluation (e.g., HBV viral load testing), care, treatment, and other services, as appropriate (69--71). Persons who are HBsAg-positive and who perform exposure-prone procedures should seek counsel from a review panel comprised of experts with a balanced perspective (e.g., HCPs' personal physicians and infectious disease specialists) regarding the procedures that they can perform safely. They should not be excluded from work (69). Persons who were infected in the past (anti-HBc-positive but negative for HBsAg) require no vaccination or treatment. 4

Ask OSAP does not provide medical or legal advice. It is recommended that you contact your area OSHA office or attorney for further information on this matter.

Please note that there may be varying requirements in those states with State OSHA Programs. It is recommended that you contact OSHA in your state to find out if there are any different requirements. Further information about State OSHA Programs can be accessed at https://www.osha.gov/dcsp/osp/index.html  .Once again, any further questions on this topic should be directed to your area OSHA office.

Resources

1)     Miller CH. Infection Control and Management of Hazardous Materials for the Dental Team, 5th edition. Elsevier/Mosby Publishers. Page 49.

2)     US Department of Labor – Occupational Safety and Health Administration. 1910.1030 Bloodborne pathogens Standard. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051   Accessed on May 17, 2016.

3)     US Department of Labor – Occupational Safety and Health Administration. Hepatitis B Vaccination Protection. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact05.html   Accessed on May 17, 2016.

4)     US Centers for Disease Control and Prevention. Immunization of Health-Care Personnel: Recommendations of the Advisory Committee on Immunization Practices (ACIP). http://www.cdc.gov/mmwr/preview/mmwrhtml/rr6007a1.htm   Accessed on May 17, 2016.

5)     US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. https://www.osha.gov/dcsp/osp/index.html    Accessed on May 18, 2016.  

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