Recently, I’ve dealt with some level of confusion surrounding the Hepatitis B vaccinations (HBV) and post-vaccination testing requirements. So in this episode of Talking with the Toothcop, I’m going to cover what both OSHA and the CDC require for the HBV and post-vaccination testing.
Outline of This Episode
- [2:03] Hepatitis B vaccination requirements in dentistry
- [5:08] OSHA requirements for post-vaccination testing
- [10:22] Hepatitis B vaccination recap
Hepatitis B Vaccination Requirements
When a dental office hires a new person, they need to determine if that person will have exposure to bloodborne pathogens. Front office staff may have exposure in one dental office and others won’t, whereas a clinical staff will have ongoing exposure. It all depends on the activities of your staff and whether or not they’re cross-trained. But it’s not like a bloodborne pathogen follows the rules and won’t cross into an area they’re not supposed to.
If a new staff member will likely face exposure throughout their employment, they need to be offered the Hepatitis B vaccination. The employer must:
- Get a copy of the employee’s vaccination record
- If the employee declines the vaccination, they must sign a declination form. (i.e. they may have already had the vaccination).
Dentists, you must show you offered the vaccination within 10 days of hiring the new staff member. Document your attempt to get the vaccination records. Include all of this in your new hire paperwork.
The vaccination is a three-shot series given over six months. At the conclusion, your staff member’s blood needs to be tested to ensure they’ve developed antibodies for Hepatitis B.
OSHA requirements for post-vaccination testing
In a 2000 OSHA response to Christopher S. Taylor, M.D. (a flight surgeon), OSHA stated that:
“The employer shall make available the hepatitis B vaccine and vaccination series to all employees who have occupational exposure, and post-exposure follow-up to all employees who have had an exposure incident." (Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, [CPL 2-2.69])
In short, according to OSHA, the employer must pay for post-vaccination evaluation and follow-up at no cost to the employee (2 months after the vaccination series is complete).
In 2015, Richard L. Raimondo, Jr. D.D.S, posed two questions to OSHA.
Dr. Raimondo also asked if anyone hired before this standard was in effect must be tested for antibodies and offered the vaccination series. OSHA responded that at the time, they didn’t recommend further vaccinations or titer testing for anyone vaccinated before December 26, 1997. However, for anyone vaccinated after December 26th, 1997, they did recommend anti-HBs [titer] testing.
Hepatitis B vaccination requirement recap
What does this mean for dentists?
- Determine who needs to be vaccinated.
- Offer them the vaccination and prove you’ve made the offer (i.e. declination form and vaccination record).
- Document, document, document. If it isn’t written, it didn’t happen.
Resources & People Mentioned
- Learn more about protectIt dental at https://dentalcompliance.com/drugkit or call them at 888-878-8916 and tell them that the Toothcop sent you!
- Check out ProEdge Dental for waterline testing!
- OSHA response to Richard L. Raimondo, Jr., D.D.S
- OSHA response to Christopher S. Taylor, M.D.
- Guidance for Evaluating Health-Care Personnel for Hepatitis B Virus Protection and for Administering Postexposure Management