Hepatitis B Vaccine: The Employer’s Responsibility

By Katherine Schrubbe,
RDH, BS, M.Ed, PhD

By Katherine Schrubbe, RDH, BS, M.Ed, PhD

Protecting staff and patients from bloodborne disease is a primary concern among your customers

Editor’s note: The following is part two of a two-part overview of the Bloodborne Pathogens Standard (BBP). Part one reviewed the first section of the Standard, including the importance of maintaining a current Exposure Control Plan in the dental practice; the meaning of universal precautions; the difference between engineering controls and safe work practices; and an overview of the Standard’s position on personal protective equipment (PPE). Part two looks at the Hepatitis B vaccine and the employer’s responsibility, including the use of signs and labels, training and record keeping.


Hepatitis B is a serious liver disease, which can be acute or chronic, and is a major contributing factor for liver cancer. Up to 2.2 million people are living with chronic Hepatitis B, and many are not aware of their infection.1

The Hepatitis B virus (HBV) is 50–100 times more infectious than HIV2, and dental patients who present with this infection can be a risk to dental providers. HBV is transmitted when blood, semen or another body fluid from a person infected with the HBV enters the body of someone who is not infected.3 HBV transmission in a dental healthcare setting is rare, particularly since standard precautions and routine vaccinations for dental workers were adopted (1985 and 1987, respectively).4

The best way to prevent an HBV infection is to be vaccinated. Hepatitis B vaccine has been successfully integrated into the childhood vaccination schedule, contributing to a 96 percent decline in the incidence of acute Hepatitis B in children and adolescents.6 The BBP Standard requires employers to offer the vaccine series to all workers who have occupational exposure, at no cost and at a reasonable time and place.5 The vaccine must be offered after employees have had initial training and within 10 days of their initial assignment, unless a worker has previously been vaccinated, antibody testing confirms immunity or the vaccine is contraindicated for medical reasons.5 If a new employee declines the vaccine, a signed declination form must be on file, stating that the worker declining the vaccine will be at risk for acquiring hepatitis B, and if he or she wants to receive the vaccine at a later date, the employer will make it available under the same initial terms.5

Post-exposure follow-up
There is an old saying: Nothing ever happens until it happens to you. Even an experienced practitioner can have an accident and sustain an occupational exposure. The BBP has a provision in place to take care of workers in such situations. The employer has to make post-exposure follow-up available to any worker who sustains an occupational exposure. The medical evaluation is at no cost to the employee and includes documentation describing how the exposure occurred.

The Standard states, “The source individual’s blood shall be tested as soon as feasible and after consent is obtained in order to determine HBV and HIV infectivity. If consent is not obtained, the employer shall establish that legally required consent cannot be obtained. When the source individual’s consent is not required by law, the source individual’s blood, if available, shall be tested and the results documented.

When the source individual is already known to be infected with HBV or HIV, testing for the source individual’s known HBV or HIV status need not be repeated. Results of the source individual’s testing shall be made available to the exposed employee, and the employee shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.

Collection and testing of blood for HBV and HIV serological status: The exposed employee’s blood shall be collected as soon as feasible and tested after consent is obtained. If the employee consents to baseline blood collection, but does not give consent at that time for HIV serologic testing, the sample shall be preserved for at least 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible. Post-exposure prophylaxis, when medically indicated, is recommended by the U.S. Public Health Service.”7

It is important to locate an occupational health clinic or a medical doctor nearby, so that a post-exposure follow-up can be completed in a timely manner.

Signs and labels
Using signs and labels to communicate hazards is the next provision of the BBP Standard. Biohazard labels should be affixed to regulated waste containers and any other containers that store, transport or ship blood or other potentially infectious materials (OPIM), as well as refrigerator and freezers containing blood or OPIM. Red bags or red containers may be substituted for labels.7,8 It is important for all dental team members to understand what these labels mean and to be cognizant of the contents.

Training
Training is integral to maintaining worker safety in the dental setting. Training for employees with occupational exposure is critical. The BBP Standard states that training must take place upon initial hire and then at least annually thereafter, at no cost to the worker and during work hours. This training must also allow for questions from workers, and it must be provided at an educational level and in a language the workers understand.7,8 Training records must include the date of training, the name of the person who conducted the training and the names/job titles of employees. The records must be saved for three years.7

The BBP Standard, Code of Federal Regulations 29 CFR 1910.1030, is comprehensive and follows OSHA’s mission to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.9

Maintaining records
In addition to addressing accurate labeling and training, the Standard includes a provision for the employer to maintain employee medical and training records. Medical records must be kept confidential and include information on the employees’ hepatitis B vaccine status; all results of examinations, medical testing and follow-up procedures; and medical opinions from healthcare professionals. According to the BBP, medical records must be kept for at least the duration of employment, plus 30 years.7

Lastly, a sharps injury log for the recording of percutaneous injuries from contaminated sharps must be maintained. The log should include the type and brand of the device, the area where the injury occurred and how the injury occurred, and it should protect the confidentiality of the injured employee.7 If the dental practice has had 10 or fewer employees at all times during the last calendar year, the owner does not need to keep OSHA injury and illness records, unless OSHA or the Bureau of Labor Statistics informs him or her in writing that records must be maintained.10


  1. US Department of Health and Human Services. Centers for Disease Control and Prevention. https://www.cdc.gov/nchhstp/newsroom/docs/factsheets/viral-hep-liver-cancer.pdf. March 2016. Accessed January 18, 2017.
  2. US Department of Health and Human Services. Centers for Disease Control and Prevention. https://www.cdc.gov/hepatitis/hbv/bfaq.htm. Accessed January 18, 2017.
  3. US Department of Health and Human Services. Centers for Disease Control and Prevention. https://www.cdc.gov/hepatitis/hbv/. Accessed January 19, 2017.
  4. US Department of Health and Human Services. Centers for Disease Control and Prevention. https://www.cdc.gov/oralhealth/infectioncontrol/factsheets/hepb.htm. Accessed January 19, 2017.
  5. United States Department of Labor. Occupational Safety and Health Administration. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact05.pdf. Accessed January 19, 2017.
  6. US Department of Health and Human Services. Centers for Disease Control and Prevention. https://www.cdc.gov/hepatitis/hbv/vaccadults.htm. Accessed January 19, 2017.
  7. United States Department of Labor. Occupational Safety and Health Administration. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051. Accessed January 19, 2017.
  8. United States Department of Labor. Occupational Safety and Health Administration. https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact01.pdf. Accessed January 19, 2017.
  9. United States Department of Labor. Occupational Safety and Health Administration. https://www.osha.gov/about.html. Accessed January 19, 2017.
  10. United States Department of Labor. Occupational Safety and Health Administration. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9632. Accessed January 19, 2017.

Editor’s Note: Katherine Schrubbe, RDH, BS, M.Ed, PhD, is director of quality assurance at Milwaukee, Wisc.-based Dental Associates.

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