Health clearance and immunisation

Under the Health and Safety at Work etc. Act 1974 [1] and the Control of Substances Hazardous to Health (COSHH) Regulations 2002 [2] employers are required to protect staff and others and to assess and minimise the risks from exposure to hazardous substances, including biological agents (see Health and Safety Legislation and Hazardous Substances (COSHH) for further details).

Integrated guidance on health clearance for healthcare workers provides information on:

health clearance measures required to minimise the risk of transmission of infection to patients from healthcare staff.
immunisation against infectious diseases required for the protection of staff. This includes Hepatitis B immunisation for staff whose activities place them at risk of this infection.

Management of effective employee immunisation via Occupational Health Services (OHS) is recommended in Scotland. In June 2018, an NHS based Occupational Health Advice and Guidance service for members of the practice team was introduced. These services are provided by NHS Boards and further information, including eligibility, available services and contact details was provided via a CDO letter.

Safe working practices

Adoption of safe working practices is the most effective method of reducing risks. Immunisation should never be regarded as a substitute for good practice. It is vital to emphasise to staff the importance of safe practice including an awareness of routine infection prevention and control precautions such as hand hygiene and appropriate use of PPE (gloves, aprons, visors etc). This can help reduce the risks of occupational exposures to blood and body fluids, including sharps injuries such as needles. Dentists and Dental Care Professionals have a legal obligation to ensure risks from sharps injuries are controlled and safe sharps practice is followed as per the Health and Safety (Sharp Instruments in healthcare) Regulations (2013) [3] (also see Occupational Exposure Management (including Sharps)).

Staff should be reminded to always comply with local policies relating to infection prevention and control to protect themselves and their patients. Local policy documentation should be explained and be easily accessible, with training provided where required.

Confidentiality

Healthcare workers must receive the same right to confidentiality as any patient seeking or receiving medical care. OHS staff work within strict guidelines on confidentiality. Their role involves continuous revision of local procedures regarding health clearance and immunisation against infectious diseases.

OHS records are held separate from any other records such as hospital, GP, HR etc. and OHS staff have an ethical and professional obligation not to release information without the informed consent of the individual. However, should patients be, or have been, at risk, it may be necessary in the public interest for the employer to have access to confidential information relating to their staff member.

Practices are required to keep records of the health clearance status of its members of staff confidential. OHS notices of fitness for clinical work (sometimes referred to as a ‘fit-slip’) do not include potentially sensitive employee health information, such as details of individuals’ vaccination history or immunity. Adopting this approach means that dental practices can avoid the need for elaborate information governance measures to maintain confidentiality.

Further information can be sourced from the Data Protection Act 2018 [4], NHS Scotland Caldicott Guardians: Principles into Practice [5] and Information Commissioner’s Office Guide to the UK General Data Protection Regulation (UK GDPR) [6].

Safe working practices

Confidentiality

Sources of information