Well Pharmacy: Hepatitis B immunisation

It has been brought to the PDA’s attention that some employees of Well Pharmacy may have been asked to start providing flu vaccinations despite not having been immunised to protect against Hepatitis B. We understand there is currently a national shortage of Hepatitis B Vaccine in the UK.

Thu 20th September 2018 PDA Union

By law, employers have a duty of care toward employees who are at risk of exposure to blood-borne viruses, e.g. through accidental injury from contaminated sharp instruments. Employers are required to assess the risks and to apply measures to prevent or control the risks of exposure, and to provide Hepatitis B vaccinations free of charge.

Employers must provide advice on the risks to employees who decide not to be vaccinated. Employers must provide appropriate training and make employees aware of the risks associated with the handling and disposal of clinical waste and ensure that correct procedures are used to minimise those risks, and they must put in place a needle stick injury procedure. Records of vaccinations of employees should be kept, and outcomes should be monitored.

The PDA cannot recommend that members put themselves at risk of Hepatitis B infection by forgoing appropriate vaccination in the interests of delivering a service Well is encouraging them to provide. Our advice to any concerned member whose employer requests them to provide vaccination services but who has not been immunised against Hepatitis B, or who requires the booster dose which is recommended five years after primary immunisation, would be to write to their employer to the effect that the request is unreasonable.

Members with concerns should not sign the relevant Patient Group Direction to agree to provide the service until the required Hepatitis B vaccination has been provided. In the event of ongoing pressure to provide the service prior to being immunised to protect against Hepatitis B, members should consult the PDA Employment Legal Advisory team (telephone 01216947000) for advice on raising a formal grievance.


“Blood-borne viruses (BBV)” HSE website

“Blood-borne viruses in the workplace — Guidance for employers and employees” HSE; Date of publication: 2001 ISBN: 9780717620623 Series code: INDG342

Hepatitis B downloadable PDF. Joint Committee on Vaccination and Immunisation (2006). “Chapter 18 Hepatitis B”. Immunisation Against Infectious Disease 2006 (“The Green Book”) (PDF) (3rd edition (Chapter 18 revised 10 October 2007) ed.). Edinburgh: Stationery Office. p. 468. ISBN 0-11-322528-8. Archived from the original on 7 January 2013.

The Control of Substances Hazardous to Health Regulations 2002

‘Flu Vaccination Advanced Service 2018/19: “Service specification — Community pharmacy seasonal influenza vaccination advanced service August 2018, NHS England Publications Gateway Reference: 08291”; and Secretary of State Directions “The Pharmaceutical Services (Advanced and Enhanced Services) (England) (Amendment) (No. 2) Directions 2018”.

The Pharmacists' Defence Association is a company limited by guarantee. Registered in England; Company No 4746656.

The Pharmacists' Defence Association is an appointed representative in respect of insurance mediation activities only of
The Pharmacy Insurance Agency Limited which is registered in England and Wales under company number 2591975
and is authorised and regulated by the Financial Conduct Authority (Register No 307063)

The PDA Union is recognised by the Certification Officer as an independent trade union.

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