Hepatitis B Vaccination and Post-Exposure Follow-Up Procedures

Q. Who must be offered the hepatitis B vaccination?

A. The hepatitis B vaccination series must be made available to all employees who have occupational exposure. The employer does not have to make the hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune as their antibody tests reveal, or who are prohibited from receiving the vaccine for medical reasons.

Q. When should the hepatitis B vaccination be offered to employees?

A. The hepatitis B vaccination must be made available within 10 working days of initial assignment, after appropriate training has been completed. This includes arranging for the administration of the first dose of the series. In addition, see page 17 for vaccination of designated first aiders.

Q. Can pre-screening be required for hepatitis B titer? Post-screening?

A. No. The employer cannot require an employee to take a pre-screening or post-vaccination serological test. An employer may, however, decide to make pre-screening available at no cost to the employee. Routine post-vaccination serological testing is not currently recommended by the CDC unless an employee has had an exposure incident, and then it is also to be offered at no cost to the employee.

Q. If an employee declines the hepatitis B vaccination, can the employer make up a declination form?

A. If an employee declines the hepatitis B vaccination, the employer must ensure that the employee signs a hepatitis B vaccination declination. The declination’s wording must be identical to that found in Appendix A of the standard. A photocopy of the Appendix may be used as a declination form, or the words can be typed or written onto a separate document.

Q. Can employees refuse the vaccination?

A. Employees have the right to refuse the hepatitis B vaccine and/or any post-exposure evaluation and follow-up. Is important to note, however, that the employee needs to be properly informed of the benefits of the vaccination and post-exposure evaluation through training. The employee also has the right to decide to take the vaccination at a later date if he or she so chooses. The employer must make the vaccination available at that time.

Q. Can the hepatitis B vaccination be made a condition of employment?

A. OSHA does not have jurisdiction over the issue.

Q. Is a routine booster does of hepatitis B vaccine required?

A. Because the U.S. Public Health Service (USPHS) does not recommend routine booster doses of hepatitis B vaccine, they are not required at this time. However, if a routine booster dose of hepatitis B vaccine is recommended by the USPHS at a future date, such booster doses must be made available at no cost to those eligible employees with occupational exposure.

Q. Whose responsibility is it to pay for the hepatitis B vaccine?

A. The responsibility lies with the employer to make the hepatitis B vaccine and vaccination, including post-exposure evaluation and follow-up, available at no cost to the employees.

Q. What information must the employer provide to the healthcare professional following an exposure incident?

A. The healthcare professional must be provided with a copy of the standard, as well as the following information:

• A description of the employee’s duties as they relate to the exposure incident;

• Documentation of the route(s) and circumstances of the exposure;

• The results of the source individual’s blood testing, if available; and

• All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer’s responsibility to maintain.

Q. What serological testing must be done on the source individual?

A. The employer must identify and document the source individual if know, unless the employer can establish that identification is not feasible or is prohibited by state or local law. The source individual’s blood must be tested as soon as feasible, after consent is obtained, in order to determine HIV and HBV infectivity. The information on the source individual’s HIV and HBV testing must be provided to the evaluating healthcare professional. Also, the results of the testing must be provided to the exposed employee. The exposed employee must be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.

Q. What if consent cannot be obtained from the source individual?

A. If consent cannot be obtained and is required by state law, the employer must document in writing that consent cannot be obtained. When the source individual’s consent is not required by law, the source individual’s blood if available shall be tested and the results documented.

Q. When is the exposed employee’s blood tested?

A. After consent is obtained, the exposed employee’s blood is collected and tested as soon as feasible for HIV and HBV serological status. If the employee consents to the follow-up evaluation after an exposure incident, but does not give consent for HIV serological testing, the blood sample must be preserved for 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested for HIV, testing must be done as soon as feasible.

Q. What information does the healthcare professional provide to the employer following an exposure incident?

A. The employer must obtain and provide to the employee a copy of the evaluating healthcare professional’s written opinion within 15 days of completion of the evaluation. The healthcare professional’s written opinion for hepatitis B is limited to whether hepatitis B vaccination is indicated and if the employee received the vaccination. The written opinion for post-exposure evaluation must include information that the employee has been informed of the results of the evaluation and told about any medical conditions resulting from exposure that may further require evaluation and treatment. All other findings or diagnoses must be kept confidential and not included in the written report.

Q. What type of counseling is required following an exposure incident?

A. The standard requires that post-exposure counseling be given to employees following an exposure incident. Counseling should include USPHS recommendations for prevention of HIV. These recommendations include refraining from blood, semen, or organ donation; abstaining from sexual intercourse or using measures to prevent HIV transmission during sexual intercourse; and refraining from breast feeding infants during the follow-up period. In addition, counseling must be made available regardless of the employee’s decision to accept serological testing.

Q. What information about exposure incidents is recorded on the OSHA 300 Log?

Revision 10/02 A. All work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious materials must be recorded. Enter the case on the 300 Log as an injury. To protect the employee’s privacy, do not enter the employee’s name. Enter the case on the sharps injury log or enter comparable data on the OSHA 300 Log.