Hepatitis: To B or Not To B

Read this information very carefully and ensure that the individual in your facility who is responsible for offering the Hepatitis B vaccine to your workers understands this added obligation.  This requirement assists in ensuring that workers have responded to the Hepatitis B vaccine, thus having full protection.  Also, according to the Centers for Disease Control and Prevention (CDC) a positive result eliminates the need for a booster for Hepatitis B.

Most dental laboratory owners offer the Hepatitis B Vaccine to all employees and this action is to be admired as it is going above and beyond the OSHA requirements.  The actual requirements under the Bloodborne Pathogen Standard is that employers offer the vaccine to employees who have the potential of exposure to bloodborne pathogens.  At Safelink, we have defined those risk areas as pick-up and delivery, receiving, model department and die trim for those who work on clinically poured models, denture repair, and shade taking.  You need a written procedure for determining which job classifications provide this potential risk.  If you use Safelink’s written health and safety training program, you are using the job description and hazard review form for this purpose.   

Some employers have been providing an antibody test after completion of the three vaccine series, but all of you must add this procedure to complete the requirements imposed upon you by OSHA. 

    * The following information is referenced from the OSHA Compliance Directive in the Bloodborne Pathogens Standard, 29CFR 1910.1030, Paragraph (f)(1)(ii)(D) and takes into consideration the changing nature of medical treatment relating to Hepatitis B. The CDC is the U.S. Public Health Service (USPHS) agency responsible for issuing guidelines and making recommendations regarding infectious agents. OSHA requires employers to follow the CDC guidelines current at the time of the evaluation or procedure. Copies of the current guidelines and other CDC documents can be obtained on CDC's web site, http://www.cdc.gov.

    * The Hepatitis B vaccination must be given in the standard dose and through the standard route of administration as recommended in the USPHS/CDC guidelines. The most current CDC guideline regarding Hepatitis B is Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis published in Morbidity and Mortality Weekly Report Vol 50, No. RR-11, June 29, 2001 (attached as Appendix E).  It states that employees who have ongoing contact with patients or blood and are at ongoing risk for percutaneous injuries are to be tested for antibody to Hepatitis B surface antigen, one to two months after the completion of the three-dose vaccination series. Employees who do not respond to the primary vaccination series must be revaccinated with a second three-dose vaccine series and retested, unless they are HbsAg-positive (infected). Non-responders must be medically evaluated.

Here are some questions to help you evaluate if your policy on the offering of the Hepatitis B vaccine is up-to-date and adequate:

Q:      Who must be offered the Hepatitis B vaccination?

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?

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.

Q:      Can pre-screening be required for Hepatitis B titer? Post-screening?

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.

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

If an employee declines the Hepatitis B vaccination, the employer must ensure that the employee signs a Hepatitis B vaccine declination. The declination's wording must be identical to that found in Appendix A of the BP 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?

Employees have the right to refuse the Hepatitis B vaccine and/or any post-exposure evaluation and follow-up. It 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:     Is a routine booster dose of Hepatitis B vaccine required?

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?

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:     Is the person receiving the vaccination allowed to use their personal physician to receive treatment?

According to the BBP Standard, the vaccinations must be administered by a licensed health care professional. It is the employer’s responsibility to ensure that all of the expenses incurred by the employee in the course of receiving the vaccinations are paid for by the employer. It is the employer’s responsibility to ensure that the healthcare professional has a copy of the BBP standard, the details of the incident and any medical records applicable to the case.

In summary, review the above and ensure that your policy for offering and providing this vaccine are in order.  One of our sources at OSHA has informed us that OSHA is citing employers for not offering the titer or antibody test as indicated above.  Remember, however, that even though the workers in risk areas have received the vaccine that the best precaution is through good infection control procedures such as sanitizing work areas, disinfecting anything that has been in the patient’s mouth, and wearing personal protective equipment to protect the worker.  Education of workers on these risks and how to protect themselves is the best prevention.