Written medical opinion before hepatitis B vaccination

December 2, 1996

David Gude, M.D.
Director of Professional Services
Texas MedClinic
[Recipient address omitted]
Dear Dr. Gude:

Thank you for your letter dated October 15, where you raised an issue relating to the Occupational Safety and Health's Administration (OSHA) standard on Occupational Exposure to Bloodborne Pathogens. You have asked about the specific requirement to obtain a healthcare professional's written opinion in the "pre-exposure vaccination setting."

The Bloodborne Pathogens standard, 29 CFR 1910.1030, requires the employer to obtain and provide the employee with a healthcare professional's written opinion of a medical evaluation prior to the initial inoculation of the Hepatitis B vaccine. This requirement can be found in paragraph (f)(5)(i). The written opinion shall be limited to whether Hepatitis B vaccination is indicated for an employee and if the employee has received such a vaccination. The second circumstance that requires a written opinion, and the one you are familiar with, is found in paragraph (f)(5)(ii). This written opinion must be obtained for post-exposure evaluations.

The purpose of obtaining an evaluation prior to receiving the vaccine is that some employees may be allergic to a component of the vaccine. Following the evaluation, the healthcare professional can proceed to administer the first inoculation on this same visit. The written opinion ensures the employer that an evaluation was done, informs the employer regarding the employee's HBV vaccination status, and allows the employer to provide a copy to the employee.

Thank you for your interest in occupational safety and health. If you have further questions, please feel free to call [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]