Inoculation (Sharps) & Blood Borne Pathogen Exposure Policy - Undergraduates

Dublin City University (DCU) is obliged, under the Safety, Health and Welfare at Work (Biological Agents) (Amendment) Regulations 2020 (S.I. No 539 of 2020), to protect employees and, specific to this policy, undergraduate students from exposure to biological hazards (as far as is reasonably practicable). 

A hazard is a potential source of adverse health effect that may result from exposure to a Biological Agent, such as a bacterium or virus, or a biological specimen, such as blood. The deployment of blood samples (or tissue samples containing traces of blood) as analytical samples for research purposes presents a risk of exposure to ‘Adventitious Agents.’ The World Health Organisation (WHO) defines Adventitious Agents as ‘microorganisms, unintentionally introduced into a process resulting in the production of a biological medicinal product.’ Direct exposure to blood, resulting from the undertaking of a placement-based project in a Hospital Setting, presents a similar risk.

A key example of an Adventitious Agents is Hepatitis B Virus (HBV).  HBV is detectable in virtually all body secretions and excretions.  Notwithstanding this fact, only blood and serum-derived fluids, semen, vaginal fluids and saliva have been shown to demonstrate infectivity potential.  The mechanism of transmission is largely believed to result from contact of mucous membranes or disrupted (non-intact) skin with blood or blood-containing products.

To minimise risk of exposure to Adventitious Agents for undergraduate students who may become exposed to blood, a secretion contaminated with blood (e.g., saliva, urine) or a biological specimen contaminated with trace amounts of blood (e.g. tissue, biopsy), there is a requirement to implement an infection control programme, which includes but is not exclusively limited to vaccination for HBV. Where undergraduate research and/or training modules may involve exposure to biohazardous material, including blood samples or pathogenic bacterial samples, immunisation acts as an adjunct to good infection control procedures, and may be an appropriate method of protection, depending on the outcomes of undertaking a risk assessment.  All undergraduate students exposed to (or potentially exposed to) such materials should be Risk-Assessed as to their requirements for receiving vaccination.  In parallel, the risks from working directly with Biological Agents or from indirect exposure to them should be communicated by their project supervisor or module coordinator.

This policy must be implemented in conjunction with all other relevant University policies, and the standard precautions to control the risk of occupational infection, as contained in Appendix A.  Hand hygiene is one of the most effective methods of preventing infection, and HSE-approved guidelines on good practice pertinent to handwashing can be found on the  HSE website.

1. To ensure that all undergraduate student researchers whose allocated research and/or training modules specifies activities involving direct contact with blood, blood-contaminated secretions (e.g., urine, saliva) or biological specimens contaminated with trace amounts of blood (e.g. tissue, biopsy) are identified as requiring immunisation, are protected by vaccination, and are serologically-tested to show adequate protection.  

2. To comply with immunisation Guidelines set by the National Immunisation Advisory Committee (NIAC), with particular emphasis on Hepatitis B vaccination.  NIAC functions to promote effective, evidence-based policies on vaccination and immunisation in Ireland. See the NIAC website for additional information.  

This Policy applies to all Schools, Research Units and wholly owned Campus Companies of the University, both academic and support, where undergraduate teaching/placement/research activities are undertaken, where there is a potential risk of exposure to blood, blood-contaminated secretions (e.g. urine, saliva) or biological specimens contaminated with trace amounts of blood (e.g. tissue, biopsy).  These are all hereinafter collectively referred to as the ‘University.’

1) Heads of Schools / Research Centres / Units are responsible for ensuring:

1. Identification of all undergraduate research, placement or training modules that may involve direct or indirect exposure to blood, blood-contaminated secretions (e.g., urine, saliva) or biological specimens contaminated with trace amounts of blood (e.g., tissue, biopsy).
2. Referral of undergraduate students who are identified as requiring vaccination to the DCU Student Health Service for immunisation. This is the recommended method of receiving immunisation for DCU students, and should be considered in preference to alternative options, such as receiving immunisation from a General Practitioner. 

2) The Research Group Principal Investigator (P.I.) or Module Coordinator is responsible for ensuring:

1. Undergraduate researchers under their remit (including visiting researchers), undertaking research, placement or training modules, that may involve direct or indirect exposure to blood, blood-contaminated secretions (e.g., urine, saliva) or biological specimens contaminated with trace amounts of blood (e.g. tissue, biopsy) are informed of the benefits of vaccination, and receive appropriate vaccinations and the necessary follow-up procedures.
2. That, in the event that an undergraduate student resource departs a project, that the replacement resource receives appropriate vaccinations and the necessary follow-up procedures.
3. That an appropriate serum-based titre for Hepatitis B Surface Antigen (HBsAg) is evident, ahead of commencing the relevant research project, placement or training module.
4. Overseeing the completion of a Risk Assessment to determine the necessity for vaccination for undergraduate researchers undertaking a research project, placement or training module where there is potential exposure to blood, blood-contaminated secretions or biological specimens contaminated with trace amounts of blood.
5. Submission of a Biological Agent Risk Assessment to the BSC and the individual School of an application to undertake undergraduate research, or the placement of training module that involves the use of a Biological Agent or Biological Sample.

3) The Vaccination Service Provider is responsible for:

1. Administering appropriate vaccinations and the necessary follow-up procedures.
2. Maintaining confidential vaccination records on behalf of the University.
3. Providing guidance and advice on immunisation.
4. Issuing/managing and retaining a record of consent/decline forms (see Appendix B, Appendix C).

4) Undergraduate students, identified as requiring vaccination (through the undertaking of a Risk Assessment) are responsible for:

1. Ensuring they are present for scheduled vaccination appointments and follow-up appointments in line contracted provider’s advice, and as directed by the Schools / Research Centres / Unit’s Risk Assessments.
2. Completing a declination form, where they decline immunisation or fail to complete a course of vaccinations identified as being necessary by their School / Research Centre / Unit Risk Assessment.

Applicable Undergraduate Modules

Current undergraduate modules where vaccination may be recommended (subject to the outcome of a Risk Assessment) are listed the following Tables 1 and 2.  In the event that any additional courses/modules are added to a curriculum, that present a risk of exposure to adventitious agents, this must be notified to the DCU Biological Safety Committee (BSC) is notified in advance of commencing these activities, so that they may be considered for inclusion herein.

Table 1. Undergraduate Research / Training Modules where Hepatitis B Vaccination may be Recommended in the School of Health and Human Performance (SHHP), including the following Research Programmes:

• ATT
• Sports Science

Table 2. Undergraduate Research / Training Modules where Hepatitis B Vaccination may be Recommended in the School of Nursing, Psychotherapy and Community Health (SNPCH), including the following Research Programmes:

• BNGN
• BNGC
• BNPY
• BNID

a) With reference to the School of Health and Human Performance (SHHP), the Laboratory Fitness Testing Module involves the collection of expired gases from a panel of cohorts (e.g., general population, athletes, clinical patience). Here, Hepatitis B vaccination would be recommended in the event that saliva is collected from a patient cohort with elevated risk of Hepatitis B or is understood to be contaminated with traces of blood.

b) With reference to the School of Health and Human Performance (SHHP) Laboratory Assessment (Hydration Status) Module, where urine is selected as an analytical sample, Hepatitis B vaccination would be recommended where urine is collected from a patient cohort with elevated risk of renal damage or Hepatitis B infection or is understood to be contaminated with traces of blood.

c) With reference to the School of Nursing, Psychotherapy and Community Health (SNPCH), there is no requirement for students to be vaccinated if they are not undertaking a placement in a hospital / service setting. If a student is on placement, each hospital / service is responsible for the provision of Occupational Health Appointments and Vaccinations to individuals undertaking these placements. Here, evidence of the Bacillus Calmette-Guérin (BCG) vaccine – or QuantiFERON Test, may be requested by the hosting entity prior to the commencement of the placement, in addition to evidence of the Measles, Mumps and Rubella (MMR) vaccine, Varicella (Chicken Pox) immunity and evidence of immunity to Hepatitis B and C.

Applicable Research Projects

a) With reference to the School of Health and Human Performance (SHHP) laboratory-based assessments of aerobic and anaerobic fitness, undergraduate Final Year Projects (FYPs) may involve the collection of blood, urine, saliva or exposure to saliva in the collection of expired gases.  Here, Hepatitis B vaccination would be recommended in the event that saliva is collected from a patient cohort with elevated risk of Hepatitis B or is understood to be contaminated with traces of blood.

b) For the School of Biotechnology, and the National Institute for Cellular Biotechnology, emphasis will be placed on undertaking final year / undergraduate projects that do not present a risk of exposure to adventitious agents, such as Hepatitis B Virus. However, in cases where this is mandatory, the undertaking of Final Year Projects involving the selection of blood as an analytical sample, or the use of biological tissue that may contain traces of blood, will only be permitted to proceed with formal approval from the DCU Biological Safety Committee (BSC), with students informed of the benefit of receiving Hepatitis B Vaccination.

c) Policy guidelines outlined herein are also applicable to other Schools and Research Centres within DCU where vaccination for Hepatitis B Virus may be considered, subject to the outcome of a Risk Assessment.

d) The vaccination status should be monitored by the Principal Investigator, to ensure that adequate primary protection is provided ahead of commencing research activities.

Records Retention

Records of vaccination will be retained in instances where the student provides consent on the form entitled: Hepatitis B Vaccination Sample Consent (Appendix B) or Decline Form (Appendix C). Where consent is provided, a record of the vaccination status is shared with the School of Health and Human Performance (SHHP) for the purpose of laboratory practical sessions.

Vaccination Guidelines

Although vaccination confers additional protection against infection, it must never be considered the primary defence because:

• not all infections can be treated by vaccination;
• immunisation may be partial, where some individuals receive inadequate protection;
• some persons may demonstrate unsuitable side effects to the vaccine; &
• there may be contraindications.

Vaccination is not mandatory, but undergraduate students should be informed of its benefits and possible disadvantages.  Where an undergraduate student declines vaccination, a consent form must be signed by them.  In some cases, where vaccination is identified as being highly desirable by the University, but is declined by the undergraduate student, and where other risk reduction controls are not reasonably possible to implement practicably, it may be necessary to relocate the undergraduate student away from the risk of exposure, or to participate in an observational capacity only.

Where vaccination is required, this includes the administration of follow-up boosters (to elevate antibody titres), and other relevant measures for as long as the risk is of exposure is thought likely.  Specific to this policy, and as outlined above, a serum-based anti-Hepatitis B Surface Antigen (HBsAg) titre is desirable ahead of commencing a research project, placement or training module where there is potential exposure to blood, blood-contaminated secretions or biological specimens contaminated with trace amounts of blood.

When should Hepatitis B vaccination be conducted?

The risks of exposure to adventitious agents in blood samples, or biological specimens containing trace amounts of blood (e.g., saliva, urine, tissue) must be fully assessed by the research group Principal Investigator or Module Coordinator ahead of commencing the intended activity (see Responsibilities, above). These risks should be fully discussed with each individual and their supervisor, mediated through engagement with the designated contract provider.  Vaccination must be conducted before exposure to the Biological Agent(s) begins. However, post-exposure vaccination may occasionally be indicated.

Who conducts the vaccination?

Vaccine administration may only be provided by the Selected Vaccine Provider, specifically the DCU Student Health Centre. 

What if I have already been vaccinated?

If you have received vaccination and intend to complete an Undergraduate Research / Training Module specified in Table 1, the continued efficacy of immunisation will be assessed by a competent person. This normally requires documentary evidence of the type of vaccine and dates of administration.

Any queries regarding this policy should be directed to the DCU Health and Safety Office, or Biological and General Safety Officer.

This policy will be reviewed every 3 years, or in the event of changes in national guidelines / local practice.