Hepatitis B Immunisation for Occuptational Health

Please see below extract from current GPC advice on Hep B administration. The full document can be download here Hepatitis B for employers - August 2005

Hepatitis B immunisation for employees at risk

The GPC receives many enquiries about administering Hepatitis B, particularly for occupational health purposes. We recognise that requests for immunisation against Hepatitis B do present considerable difficulties for practices. This guidance summarises our legal advice on the interpretation of the GMS, PMS and APMS Regulations and directions.

Is there a requirement under regulations to prescribe and administer Hepatitis B vaccination for occupational health purposes?

It could be argued that there may be an obligation under paragraph 15 of the new GMS Regulations to provide Hepatitis B to patients. Paragraph 15(3) of the GMS regulations requires GPs to manage their patients and paragraph 15(4) defines management as:

1. Offering consultation and, where appropriate, physical examination for the purpose of identifying the need, if any, for treatment or for further investigation; and
   
2. The making of such treatment or further investigation as is necessary and appropriate, including the referral of the patient for other services under the Act and liaison with other health care professionals involved in the patient’s treatment and care.
   

This definition also applies to PMS and APMS. Firstly it is the employer’s duty under Health and Safety Legislation to assess whether the provision of Hepatitis B is necessary, therefore a doctor does not have a duty under paragraph 15 4(a) to conduct an examination to determine whether the vaccination is required.

Secondly, in practise, it would be very difficult for a GP to know whether provision of the vaccination is necessary and appropriate, in the absence of guidance from an appropriate specialist. In the absence of such guidance, it would not be appropriate for the GP to provide the vaccination and therefore paragraph 15(b) would not apply.

Accordingly, the GPC’s view is that there is not an obligation under the regulations governing GP contracts to administer such vaccinations for occupational reasons. Patients should be referred to the Employer’s Occupational Health Department.

The same applies for healthcare students who often request a Hepatitis B immunisation prior to, or on entering, a course. Medical Schools are legally responsible for providing a full occupational health service to their students. This should include appropriate training for example in risk reduction and coping with needle stick injuries. By providing a Hepatitis B immunisation, a GP could place inexperienced healthcare students at risk by providing a false sense of security and potentially exposing them to clinical risk of other blood borne infections including HIV and Hepatitis C before they have received appropriate training.

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