Vaccination Policy for Staff

DCU is obliged, under the Safety, Health and Welfare at Work (Biological Agents) Regulations 2020 (S.I. No 539 of 2020), to protect employees, so far as is reasonably practicable, from exposure to Biological Agents in the workplace. Biological Agents are defined as microorganisms, cell cultures or human endoparasites, whether or not genetically-modified, which may cause infection, allergy, toxicity or otherwise create a hazard to human health.  A hazard is a potential source of adverse health effect.

This requires the application of an infection control programme, which includes vaccination.  All staff exposed to (or potentially exposed to) biological agents should be 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 fully-discussed with each individual and their supervisor, and the necessary course of action must be taken before exposure to biological agents begins to reduce the biohazard risk (e.g. the likelihood that the person will may be harmed, or suffer an adverse health effect upon exposure to a hazard).

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 referenced at this link.

Immunisation provided as a mechanism of protecting staff 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.  Where identified as being necessary by the School / Research Centre / Unit risk assessment, new employees will be provided with guidelines on how to receive vaccination by the University’s Contracted Provider.

1. To ensure that all staff (including Postgraduate and Postdoctoral laboratory-based staff, and those involved in work-related overseas travel) 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).  The NIAC works to promote effective, evidence-based policies on vaccines and immunisation in Ireland, and Additional information on NIAC policy may be accessed at this link.

This Policy applies to all units of the University, both academic and support, including its research centres and its wholly owned campus companies. These are all hereinafter collectively referred to as the ‘University’.

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

• Referral of ‘at-risk’ employees to the contracted provider for immunisation.

2. The Research Group Principal Investigators (P.I.) are responsible for ensuring:

• Staff members, including Postgraduate and Postdoctoral researchers under their remit, receive appropriate vaccinations and the necessary follow-up procedures.
• The provision of a project sub-cost to support the cost of vaccine administration.
• For ensuring that, in the event that a resource departs a project, that the replacement resource receives appropriate vaccinations and the necessary follow-up procedures.
• Overseeing the completion of a Risk Assessment to determine the necessity for vaccination.

3. The Contracted Provider is responsible for:

• Administering appropriate vaccinations and the necessary follow-up procedures.
• Maintaining confidential vaccination records on behalf of the University.
• Providing guidance and advice on immunisation.
• Issuing/managing and retaining a record of consent/decline forms.

4. Employees are responsible for:

• 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 / Units Risk Assessments.
• Completing a decline 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.
• To declare visits to high-risk areas that require travel vaccination, be it work-related or for personal travel.

Eligible Staff Members

Staff members for whom vaccination may be recommended (post-consultation with the University’s Contracted Provider) are listed below, in Table 1.

Table 1. University Staff for whom Vaccination may be recommended.

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 staff should be informed of its benefits and possible disadvantages. Where a staff member (including a postgraduate or postdoctoral laboratory-based staff member) 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 staff member, and where other risk reduction controls are not reasonably possible to implement practicably, it may be necessary to relocate the individual away from the risk of exposure.

Where vaccination is required, this will be offered free-of-charge to the individual, and arranged and approved by management. 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.

Where staff have received prior and adequate immunisation before the present risk assessment, the continued efficacy of immunisation will be assessed by a competent person, such as a physician. While pre-employment immunisation will not be required as a condition for employment, pre-employment, pre-exposure vaccination should be offered to staff where the risk assessment indicates such a measure should be implemented. Post-exposure prophylaxis may be occasionally medically-indicated.

When should vaccination be conducted?

The risks from working directly with biological agents, or from indirect exposure to them, must be fully-assessed by the research group Principal Investigator (see Responsibilities, above) and should be fully-discussed with each individual and their supervisor through engagement with the contracted 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 University’s Contracted Provider.

What if I have already been vaccinated?

If you have received vaccination (as recommended by the guidelines 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.

Hepatitis B Vaccination

Immunisation (Vaccination) against Hepatitis B is recommended for those who may be exposed to human blood / blood-stained bodily fluids in the course of their work. This includes technical and research staff, and postgraduate students who undertake laboratory-based work with blood samples.

In brief, a researcher is occupationally exposed if his / her allocated activities require him / her to work with any of the following:

1. Human blood or other human blood products.
2. Human bodily fluids (e.g. saliva, cerebrospinal fluid (CSF), synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, urine or faeces visually contaminated with blood, semen or vaginal secretions).
3. Unfixed human tissues or organs.
4. Human cell lines (primary human cell lines or continuous human cell lines that have not been shown to be free of blood-borne pathogens or other adventitious agents).
5. Animals infected with Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV) or other blood-borne pathogens (including field work with exposure to ticks or other vectors).
6. Animal or human cells, tissues or organs infected with HIV, HBV or other blood-borne pathogens.
7. Non-human primates, or unfixed material from non-human primates.
8. Non-human materials, but where the individual is using the same laboratory equipment as other individuals select to work with human blood or other potentially-infectious material.

If an individual declines vaccination for Hepatitis B, but is subsequently exposed to risk (e.g. by needlestick injury), vaccination started at that time will provide good protection.   Routine vaccination against Hepatitis B is not normally considered necessary for first-aider volunteers in DCU.  Protection conferred through the use of nitrile gloves, resuscitation devices etc. will greatly reduce this risk.

With reference to pregnancy, HBV infection in pregnant women may result in severe disease in the mother and chronic infection of the new-born. Immunisation should not be withheld from a pregnant woman if she is in a high-risk category.

Guidelines issued by the National Immunisation Advisory Committee should be followed, and these are accessible at this link.

The effects of Hepatitis B, indications/contraindications for booster vaccinations are documented in the guidelines.

Tetanus Vaccination

Immunisation against Tetanus is recommended for all work involving the use of animal models. Immunisation is strongly recommended for researchers working directly with tetanus toxin or individuals who culture Clostridium tetani or genetically-modified micro-organisms (including bacteria and viruses) engineered to express tetanus toxin or variants / derivatives / fragments that are known to be, or might be, toxic - as determined through the undertaking of a comprehensive Biological Agent Risk Assessment.  This vaccination is also recommended for those individuals who work with soil and garden equipment, such as grounds and garden staff.

Individuals who have wound injuries should be medically-assessed to determine what treatment is needed to prevent Tetanus. The treatment recommended by the DCU contracted provider will depend on the history of Tetanus vaccination, the type of wound received, whether it is considered to be a ‘Tetanus-prone wound’ (such as wounds contaminated with dirt, faeces, soil and saliva) and the likelihood of exposure to Tetanus toxin or toxin-expressing organisms in the case of researchers working directly with these agents. The Effects of Tetanus, indications / contraindications for booster vaccinations are documented in the guidelines available at this link, and issues by the National Immunisation Advisory Committee.

BCG (Bacillus Calmette Guérin) Vaccination

All occupational workers who may be exposed should have pre-employment base-line Mantoux tuberculin testing performed if there is no BCG scar present, or no documented evidence of having received a BCG vaccination.   If there is an inadequate response, then the individual will be referred to the occupational medical advisor, and a BCG vaccination will be provided.  Persons coming from countries with a high incidence of TB should be screened in accordance with the documented immigration guidelines.  The BCG vaccine contains a live attenuated strain derived from Mycobacterium bovis.

The BCG vaccine should not be given to those who are pregnant, or to those with positive tuberculin tests.

Guidelines issued by the National Immunisation Advisory Committee should be followed, and these are accessible at this link.

The effects of tuberculosis, indications / contraindications for booster vaccinations are also documented in these guidelines.

Polio Vaccination

At-risk persons include staff travelling to countries or areas where poliomyelitis is epidemic or endemic, and those in contact with specimens that may contain wild poliovirus.

Poliomyelitis vaccine is available as an Inactivated Polio Vaccine (IPV), in combination with other vaccines.  Live Oral Polio Vaccine (OPV) is no longer licensed in Ireland or European Union countries, but is used in other parts of the world. Fully-vaccinated individuals at increased risk of exposure to poliovirus should be given a single dose of Tdap / IPV.

Guidelines issued by The National Immunisation Advisory Committee should be followed, and these are accessible at this link.

The effects of poliomyelitis and indications / contraindications for booster vaccinations are documented in the guidelines.

Hepatitis A Vaccination

Immunisation against Hepatitis A should be considered for those who may be exposed to raw sewage. In the university, this applies to maintenance staff who may be required to enter drains or to clear sewerage blockages with a risk of back-splash.  Personnel in this category may be checked for Hepatitis A immunity.  If not immune, they may be offered Hepatitis A vaccination. This would also apply to laboratory researchers who culture hepatitis A virus.

Those who clean toilets or clean up spillages of human waste do not require Hepatitis A vaccination, as adequate protection can be provided by the use of protective clothing and good hygiene practices. Immunisation consists of an initial dose, followed by a booster dose, administered 6 – 12 Months later.

Guidelines issued by The National Immunisation Advisory Committee should be followed, and these are accessible at this link.

The effects of hepatitis A, indications and contraindications of the Hepatitis vaccine are documented in the guidelines.

Work-Related Travel Vaccinations

Individual travel vaccination requirements may differ and cannot be assumed.

Travel health advice and vaccination will be delivered by the contracted provider to protect the health of the staff member(s) involved in work-related overseas travel. The contracted provider will assess each individual’s requirements upon referral from Head of School, Unit or Research Centre.

Travel vaccinations will be provided by the contracted provider, in accordance with professional regulations.

Any queries regarding this policy should be directed to DCU Biological Safety Advisor.

This policy will be reviewed annually or in the event of changes in national guidelines / local practice.