Standard Interpretations - Table of Contents|
| Standard Number:||1910.1030; 1910.1030(g)(2)(vii)(I)|
|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
|MEMORANDUM FOR:||ROGER CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
|ATTENTION:||RUTH McCULLY, DIRECTOR OFFICE OF HEALTHCOMPLIANCE ASSISTANCE
|FROM:||MICHAEL G. CONNORS
|SUBJECT:||NATIONAL OFFICE RESPONSE VOCA CORPORATION|
Vaccine doses administered at longer intervals provide equally satisfactory protection, but optimal protection is not conferred until after the third dose. If the vaccine series is interrupted after the first dose, the second and third doses should be given separated by an interval of 3-5 months. Persons who are late for the third dose should be given this dose when convenient. Post vaccination testing is not considered necessary in either situation.What this means is that although the 0, 1, 6-month interval is most desirable for conferring immunity, and these are the time intervals that OSHA requires employers to follow, immunity is not completely compromised by not strictly adhering to this 0, 1, 6- month recommendation. The need for post vaccination screening is addressed on page B-14 of the recommendations.
Available data show that vaccine-induced antibody levels decline steadily with time and that up to 50% of adult vaccinees who respond adequately to vaccine may have low or undetectable antibody levels by 7 years after vaccination. Nevertheless, both adults and children with declining antibody levels are still protected against hepatitis B disease.What this means is that post-vaccination screening is not always a useful tool in identifying if persons have not acquired immunity, because it is known that over time, almost half of immune adults who are tested will notshow immunity. The best way to ensure a adequate development of antibody is to follow the USPHS recommendations. To answer your three questions regarding booster doses:
(a) whether the standard requires an employer to pay for booster doses of the vaccine for employees who fail to receive the second and or third doses of the vaccine in a timely fashion?
(b) whether an employer is permitted to require employees who fail to receive the second and third doses of the vaccine in a timely fashion to undergo post- vaccination screening prior to administration of a booster dose of the vaccine, to determine whether a booster dose is medically necessary?
(c) whether the standard requires an employer to offer the vaccine without charge to employees, who have already received the series of shots, in a timely fashion, if the employee undergoes post-vaccination screening and discovers that the employee has lost immunity to Hepatitis B?
(a) whether willful refusal by an employee to receive the second and/or third dose of the hepatitis B vaccine within the prescribed time limits, constitutes a de facto declination of the vaccine?
(b) what steps an employer must take to ensure that employees electing to participate in the vaccination program receive the vaccine in a timely fashion?
|Standard Interpretations - Table of Contents|