Veterinary Manuals - Quick Question on Hep B Vaccine for Veterinary Employees


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Suzanne Gushansky Total posts: 3 Joined: 05/10/14 08:19:45

Thank you.  This is very helpful.

Posted: 05/18/14 07:58:12
Osha Manuals Total posts: 19 Joined: 05/27/13 21:46:12

Hi Suzi,

The veterinary employers are not mandated to provide the HBV vaccinations to their employees who are not exposed to human blood as dental and medical employees do.  However, as AVMA stated in the article veterinary employers are recommended to voluntarily comply with BBP guidelines including HBV vaccinations as well.  A veterinary employer, in his or her professional judgment, makes a case for the need for HBV vaccinations due to potential exposure to human blood or OPIM, he or she must provide them to protect their employees.

Thank you for writing to us again.

Thomas Kappil

Posted: 05/12/14 11:08:10
Suzanne Gushansky Total posts: 3 Joined: 05/10/14 08:19:45

Thank you for your response.  As it is with voluntary compliance, if we are enforcing guidelines of the bbp, would this require us to offer the Hep B vaccine to our doctors and technicians?  We currently do follow universal precautions and PPE guidelnes.  Thank you in advance.


Posted: 05/12/14 00:11:00
Osha Manuals Total posts: 19 Joined: 05/27/13 21:46:12

Hello Suzi,

Thank you for writing to us.

‘Reasonably anticipated’ in the context of OSHA regulations is referring to a situation where there is sufficient likelihood for a hazard to occur. For example, the employees in a commercial laundry facility with a contract to launder contaminated linen from medical/dental settings would be considered to have reasonably anticipated exposure to blood and Other Potentially Infectious Materials (OPIM) and would be covered by the BBP standard, while a commercial laundry cleaner without such contracts where reasonably anticipated exposure to blood or OPIM is less likely to occur may not be covered by BBP standard.

OSHA has clarified that the BBP standard generally only applies to occupational exposures to human blood, blood components, and other potentially infectious materials (OPIM), unless the animal blood is known to be infected with the human immunodeficiency virus (HIV) or hepatitis B virus (HBV). However, in a February 1994 journal article (JAVMA, Vol. 204, No. 3), AVMA recommends voluntary compliance with OSHA’s bloodborne pathogens standard in order to best protect employees working in veterinary or other animal settings. Employees involved in lab research where animal blood is infected with human blood are mandated to comply with all aspects of BBP standard. 

Since you mentioned that clients who bring injured dogs covered with blood are also injured from dog bites very often, these events seem to be happening on a frequent basis. Therefore, it should be reasonably anticipated that your employee could be potentially exposed to human blood or OPIM as well. Irrespective of whether the clients are injured or not, we recommend that you follow OSHA’s BBP standard’s guidelines such as universal precautions and the use of PPE.  Ensuring that the employees wear PPE such as gloves, aprons, masks, etc. is a substantial step to prevent BBP transmissions in your workplace. 

I hope I have answered your question. If you have any further questions, please feel free to write to us again.


Thomas Kappil

Posted: 05/10/14 22:29:05
Suzanne Gushansky Total posts: 3 Joined: 05/10/14 08:19:45

I have questioned this for a long time.  I have been managing OSHA compliance and developed a program for a Veterinary Hospital in CA.  What is the definition of "reasonably anticipated"?  I still do not know.  My concern is when a client comes in with a dog who has been in, for example, a dog fight, and is covered in blood, the first question I train my staff to ask the client is if they have been injured themselves.  Very often clients get bit during the fight.  My employees are required to apply gloves before retrieving the patient from the client.  So is this considered "reasonably anticipated"?  Or because we are not actually in the business of treating the client for wounds does the bbp standard not apply? 

Thank you.


Posted: 05/10/14 08:19:45
Osha Manuals Total posts: 1 Joined: 07/24/13 22:52:08

Hi Sherry,

If your staff is not exposed to human blood or animal blood infected with hepatitis B virus used for human research, then you do not need to comply with the hepatitis B part of the bloodborne pathogen (BBP) standard. Thank you very much for writing to us.

Posted: 07/24/13 22:52:08
Sherry Gutwein Total posts: 1 Joined: 07/24/13 15:08:05

We are going through our osha manual and have a question about the Hep B section.  This is a veterinary practice.  Is it mandatory for us to have the Hep B vac.?

Posted: 07/24/13 15:08:05
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