The OSHA Bloodborne Standard applies to all employers (Principal Investigators and Supervisors) and employees that may have an exposure to human blood or other potentially infectious material, which includes human cell lines (29 CFR 1910.1030). The standard requires employers “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. Hepatitis B vaccination shall be made available after the employee has received Bloodborne Pathogen training AND within 10 working days of initial assignment to all employees who have occupational exposure (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). In addition, the employee may decline the vaccine.”
In an interpretation of the standard, OSHA has clarified that “…….employers are required to maintain an accurate copy of each employee’s hepatitis B vaccination status, including the dates of all the hepatitis B vaccinations [29 CFR 1910.1030(h)(1)(ii)(B)]. The documentation of vaccination status serves as a useful tool in assisting healthcare professionals who must administer post-exposure counseling and treatment to employees following an exposure incident…………… Employers must make every effort to obtain a reliable record of employees’ vaccination status. These efforts may include contacting the previous employer or facility where the vaccination was administered to obtain these records. As it is a requirement that all employers maintain these records for the duration of employment plus 30 years, a previous employer who administered hepatitis B vaccinations would have copies of those records [29 CFR 1910.1030(h)(1)(iv)]. If a copy of the vaccination record cannot be obtained, then OSHA recommends that documentation verifying the employer’s attempt to obtain the record be maintained. When these records cannot be obtained from the previous employer, the current employer must obtain from the employee a written statement about vaccination status, including the dates or, where this is not possible, the approximate dates of the vaccinations.”
Thus, Principal Investigators/Supervisors at the University of Utah must ensure that their employees have received the vaccination series or have signed a declination statement, unless they are already immune or the vaccine is contraindicated.
OEHS has developed a Vaccination Attestation template that Principal Investigators/Supervisors may use to document the status of employees. This form can be found here. Copies of vaccination status or declination must be maintained in the laboratory with the lab’s Exposure Control Plan and copies must be provided to the OEHS Biosafety team at Biosafety@OEHS.utah.edu. Please note that during OEHS Bloodborne Pathogen training, employees are required to complete this form and copies are provided to the employer.
For employees wishing to receive the hepatitis B vaccination, it is offered free-of-charge through the University of Utah Student Health Services. It includes three injections at prescribed intervals over a 6-month period. Contact OEHS at 801-581-6590 to arrange vaccination.
University of Utah Exposure Control Plan