CSTE POSITION STATEMENT 1991-22

COMMITTEE: Infectious Disease/Occupational/Environmental/Injury

TITLE:   Occupational Safety and Health Administration (OSHA) Interim Guideline (OSHA Instruction CPL 2-2.44B, February 27, 1990) for Preventing Occupational Exposure to Hepatitis B Virus HBV) and Human Immunodeficiency Virus (HIV)

ISSUE: Reports from multiple states indicate that the enforcement of the above guideline by OSHA has resulted in HBV vaccination of health care workers, first responders, public service workers, home health care workers, and public health nurses, where current epidemiologic surveillance data indicate that no increased risk of HBV infection exists.

POSITION TO BE ADOPTED: CSTE requests that OSHA review and justify the cost-effectiveness of universal enforcement of the guideline or standard regarding the use of HBV vaccine to prevent occupationally-acquired HBV infection based on 1) geographic variability of HBV seroprevalence in patients and workers, and 2) actual risk of blood exposure by occupational category.  Where this analysis suggests that universal HBV vaccination is not cost-effective for such individuals, alternative provisions, such as post-exposure prophylaxis, should be made within the OSHA enforcement procedure.

BACKGROUND/JUSTIFICATION: OSHA issued guidelines for the prevention of occupational exposure to HBV and HIV in February, 1990 (CPL 2-2.44B).  Specifically, OSHA set forth the enforcement procedures and interpretations of OSHA requirements with respect to the protection of workers who are exposed to blood or other potentially infectious materials.  These guidelines will be superseded after OSHA promulgates a standard on occupational exposure to bloodborne pathogens; this standard is expected to be issued in the Fall of 1991.

The guidelines currently require that HBV vaccine be offered at no cost to all employees whose jobs involve the substantial risk of directly contacting blood or other potentially infectious materials.  In addition, vaccinations shall be given according to recommendations for standard medical practices.

The initiation of uniform HBV vaccination in these groups is without regard to the actual risk of occupationally-acquired HBV infection as it relates to geographic variability or patient population risk of HBV infection.  For some groups, particularly public safety workers, first responders, and public health practitioners, support of the HBV vaccination program will require public funds.  These funds will be diverted from funds for other needed prevention programs, including neonatal HBV vaccination.