Vaccination at Work: Hepatitis B, Tetanus, Flu

What rule is workplace vaccination based on?

Vaccination at work is part of health surveillance, and its legal basis is the Regulation on the Prevention of Risks of Exposure to Biological Agents (Official Gazette 15.06.2013, No. 28678). Article 16 of the Regulation sets three basic rules:

The risk assessment carried out identifies the workers for whom special protective measures must be taken (Art. 16/2).
For workers who are not yet immune to the biological agent to which they are or may have been exposed, suitable vaccines are given where necessary, in cooperation with the Ministry of Health's competent units in the province (Art. 16/3).
When employers keep vaccines, they take into account the matters in Annex VII.

Annex VII, "Code of Practice for Protective Vaccination", contains five short principles: those exposed to a biological agent for which an effective vaccine exists are vaccinated; vaccination is carried out in line with the relevant legislation and practice; workers are informed of the benefits and drawbacks of both vaccination and non-vaccination; the cost of vaccination is not charged to the worker; and a vaccination certificate is issued for each worker, to be shown to the authorities on request.

This principle is also consistent with the general rule in Art. 4/4 of Law No. 6331: the cost of OHS measures cannot be passed on to the worker. We described biological risk groups and the levels of measures in detail in our article on biological agents and risk groups.

Occupational vaccines: which vaccine for which worker?

The list of biological agents in Annex III of the Regulation marks agents for which an effective vaccine exists with the letter "V". For example, the hepatitis B virus (Group 3), the tetanus agent Clostridium tetani (Group 2) and influenza viruses (Group 2) carry this mark. However, being on the list does not in itself mean that everyone will be vaccinated; the decision is made in the risk assessment according to the worker's job and exposure.

Worker group	Exposure	Main vaccine	Note
Physician, nurse, laboratory, dental clinic worker	Blood and body fluids, sharps	Hepatitis B	Post-vaccination immunity check planned by the physician
Patient care and cleaning staff, medical waste collectors	Blood-contaminated waste, needlestick	Hepatitis B, tetanus	Subcontractor workers are also assessed within the scope
Workers in patient and elderly care	Respiratory infections	Flu (annual)	Protects the worker and the person cared for
Construction, metalwork, recycling, agriculture, gardening	Wounds contaminated with soil and rusty metal	Tetanus	The physician sets the booster interval in adults
Waste water, treatment and sewerage work	Contamination with faeces and waste water	According to the physician's risk assessment	Vaccine choice depends on the nature of the work

The table is an example. The workplace physician decides which vaccine to recommend to which worker, also taking into account the worker's vaccination history and state of health.

Hepatitis B vaccine: the most critical vaccine in health institutions

Hepatitis B is one of the main infections that can be transmitted in health institutions through needlestick and sharps injuries. The path followed by the workplace physician is generally as follows:

Asking about vaccination and immune status on recruitment: The worker's vaccination card or records are requested; if necessary, immune status is assessed with a blood test.
Vaccination schedule: A vaccine series is started for a worker who is not immune. The physician sets and follows up the intervals between doses; an incomplete series is the most common shortcoming.
Post-series check: In workers who come into contact with blood and body fluids, it is checked after the vaccine series whether a protective antibody level has developed.
Non-responding worker: The physician may plan an additional dose or a repeat series; post-exposure follow-up of these workers is particularly important.

Vaccination does not replace the post-exposure protocol. We set out step by step what to do after a needlestick in our article on sharps injuries.

Tetanus vaccine at work: any job with a risk of injury

Tetanus is a vaccine-preventable disease that can be transmitted through wounds contaminated with soil or rust. In work where cuts and puncture wounds are common, such as construction, metal and machinery manufacturing, scrap and recycling, and agriculture and landscaping, tetanus vaccination status should be checked on recruitment. In adults, the physician determines the interval between booster doses and whether an additional dose is needed after an injury, depending on the type of wound and the person's vaccination history. A practical suggestion: add a line "was tetanus vaccination status asked?" to the first aid record; that way, when an injured worker goes to a health institution, their vaccination history is known.

How is a flu vaccination campaign planned?

The flu vaccine is renewed every year and comes up most often in health institutions, care homes and crowded working environments. A campaign can be planned with the following steps:

Scope: Identify priority groups according to the risk assessment: workers in direct contact with patients, workers with chronic diseases.
Timing: Plan it in autumn, before the flu season starts; confirm the vaccine supply date in advance.
Information: Give written information on the purpose of the vaccine, possible side effects and the consequences of not being vaccinated.
Administration: The vaccine is administered by health personnel; the place of administration, the cold chain and post-vaccination observation are planned.
Records: The date of administration and vaccine details are recorded for each worker.

How is the vaccination record kept?

Annex VII requires a vaccination certificate to be issued for each worker. The record should contain the following information:

Field	Example
Worker and job	Name and surname, department, type of exposure
Vaccine and dose	Name of the vaccine, which dose it is
Administration	Date, health personnel who administered it, place of administration
Product information	Serial or batch number of the vaccine
Next step	Date of the next dose or check
Information	Worker's signature confirming that information was given

These records are health data and are kept confidential (Law No. 6331 Art. 15/5). Under Art. 16/5 of the Biological Agents Regulation, personal medical records are kept for at least 15 years after exposure ends, and in certain special cases for 40 years from the last known exposure. We covered with whom health information can be shared in our article on worker health information and the KVKK (Personal Data Protection Law). The supervisor is told only work-related recommendations such as "this worker can work in this job under this condition", not "the vaccine series has not been completed".

What to do when a worker declines the vaccine

Annex VII requires the worker to be informed of the benefits and drawbacks of vaccination and non-vaccination; this shows that the decision is an informed choice. The Regulation provides no separate sanction for a worker who refuses the vaccine. In this case, what to do is:

Information interview: The workplace physician listens to the worker's concerns and explains why the vaccine is recommended, how exposure could occur and the possible consequences of not being vaccinated.
Written record: That information was given and that the worker declined the vaccine is recorded with a dated and signed statement. If the worker does not want to sign, the physician notes this.
Additional protective measures: Sharps safety, suitable gloves and eye protection, and arrangements in the workflow that reduce exposure are reviewed specifically for this worker.
Post-exposure plan: The route an unvaccinated worker will follow in the event of an injury or exposure is set in advance.
Fitness for work: The physician assesses under what conditions the worker can work in this role, according to the level of exposure in the job.
Offer again: A refusal is not considered permanent; the vaccine is offered again at periodic examinations.

We carry out the vaccination plan, immunity follow-up and vaccination records according to the biological risk assessment under our workplace physician service. When laboratory tests are needed, we plan them with authorised laboratories and health institutions. For other sector-specific risks, see our health institutions page.

Frequently Asked Questions

Who pays for vaccination at work?

The employer pays. Annex VII of the Biological Agents Regulation states clearly that the cost of vaccination will not be charged to the worker; Law No. 6331 also provides that the cost of OHS measures cannot be passed on to the worker.

Which workers are recommended the hepatitis B vaccine?

People who come into contact with blood and body fluids, use sharps or work with waste contaminated by them: physicians, nurses, laboratory and dental clinic workers, cleaning and medical waste staff, and so on. The decision is made by the workplace physician according to the risk assessment.

Does a worker have to be vaccinated?

The Regulation requires the worker to be informed of the benefits and drawbacks of vaccination and non-vaccination, and provides no separate sanction for a worker who refuses the vaccine. The refusal is recorded, additional protective measures are applied and the vaccine is offered again later.

How long is the vaccination record kept?

For exposure to biological agents, personal medical records are kept for at least 15 years after exposure ends; in the special cases listed in the regulation, this period is 40 years from the last known exposure.