August 1, 2007

Dr. Christopher Johnson
1381 Citrus Tower Boulevard
Suite 103
Clermont, FL 34711

Dear Dr. Johnson;

This letter is in response to your letter of January 22, 2007 concerning the potential expense involved in the administration of hepatitis B vaccinations. You ask in particular if an employer is required to start the vaccination series for a new employee over again, if the employee had not completed the scheduled shots in the series. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Employers who have employees with reasonably anticipated exposure to blood or other potentially infectious material (OPIM) are required to provide the hepatitis B vaccination series at no cost to the employee [29 CFR 1910.1030(f)(2)(i)]. The vaccination series must be provided in accordance with the recommendations of the U.S. Public Health Service current at the time of the vaccination [29 CFR 1910.1030(f)(1)(ii)(D)]. If it can be documented that a new employee has already received part of the vaccination series, the healthcare professional responsible for the employee's hepatitis B vaccination must use this information as part of the evaluation. It is usually not necessary to restart the vaccination series if an employee misses the scheduled date for a shot. Even though the usual frequency of the shots in the vaccination series is at 0, 1, and 6 months, the U.S. Public Health Service (USPHS) provides for some flexibility in scheduling. If the series is interrupted after the first dose, the second dose must be administered as soon as possible, and the second and third doses must be separated by an interval of at least 8 weeks. If only the third dose has been delayed, it must be administered as soon as possible. This permits a certain flexibility, and there should be little or no added financial burden on a reasonably diligent employer if an employee misses a date for a shot. The employer would simply reschedule the missed shot as soon as possible.

You must also have your employee tested for antibody to Hepatitis B surface antigen, one to two months after the completion of the three-dose vaccination series. Post-vaccination testing must be completed 1-2 months after the third vaccine dose for results to be meaningful. A protective antibody response is an anti-HBs concentration of 10 or more milliInternational Units per milliliter (≥10mIU/mL). 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).

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,



Richard E. Fairfax
Directorate of Enforcement Programs