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 https://www.osha.gov.

March 10, 2000

Christopher S. Taylor, M.D.
Deputy Regional Flight Surgeon
Federal Aviation Administration
Aviation Medicine
Northwest Mountain Region
1601 Lind Avenue, S.W.
Renton, WA 98055-4056

Dear Dr. Taylor:

Thank you for your February 10 letter addressed to the Occupational Safety and Health Administration's (OSHA's) [Office of Health Enforcement]. You have a question regarding whether a Hepatitis B vaccination booster is required by OSHA under the Bloodborne Pathogens Standard, 29 CFR 1910.1030. This letter supplements our phone conversation and we hope it better serves your needs.

According to the standard and the recently published directive, Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, [CPL 2-2.69], an employer's responsibility for providing the hepatitis B vaccination series is clear. Paragraph (f)(1)(i) of the standard states, "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." This includes employer provision of, "the hepatitis B vaccine and vaccination series and post-exposure evaluation and follow-up, including prophylaxis... at no cost to the employee,...at a reasonable time and place, and...according to recommendations of the U.S. Public Health Service current at the time these evaluations and procedures take place."

Regarding your letter, a hepatitis B vaccination booster is not currently required by the U.S. Public Health Service, Centers for Disease Control and Prevention's (CDC's) Guidelines for the Immunization of Health-Care Workers. However, the December 26, 1997 CDC Guidelines does indicate that "postvaccination testing for antibody to hepatitis B surface antigen (anti-HBs) response is indicated for healthcare workers who have blood or patient contact and are at ongoing risk for injuries with sharp instruments or needlesticks." This means that a titer or antibody testing is required approximately two months after the employee finishes the vaccination series. The indicated guidelines can be found in [Appendix E of CPL 2-2.69], which is available on OSHA's website at http://www.osha.gov.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you wish to obtain a hard copy of the standard or its directive, you may contact OSHA's Office of Publications at (202) 693-1888. If you have any further questions, please feel free to contact the [Office of Health Enforcement] at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs

[Corrected 10/29/02]