Mark,
You are correct - under the COSHH regulations and the biological agents Approved Code of Practice, the duty lies with the EMPLOYER to assess the risks arising from exposure to 'biological agents' and then to prevent or control exposure.
Prevention/control and/or health surveillance may well include the provision of vaccinations and checks for immune status (e.g. Hepatitis B). So if vaccinations for staff are required because of the findings of the COSHH assessment, the employer has a legal duty to provide and pay for them. HSE's current guidance is that this should be arranged through a competent medical practitioner (normally an occupational physician), and in all cases a non-confidential health record should be kept (refer to COSHH Appendix) in addition to the confidential medical record.
The physician who carries out the vaccinations should provide feedback to the employer on the outcome of any health surveillance procedure (e.g. checks on immune status), expressed in terms of fitness for work.
A Happy Christmas to all,
Linda Shelmerdine
______________________________ Reply Separator _________________________________
Subject: Re: Vaccinations Again
Author: MIME:[log in to unmask] at netmail
Date: 22/12/2000 00:05
Hi Jeremy
> Thanks for your comments. Someone once told me that if vaccinations were > necessary for employment purposes then they should be given free
> of charge.
Nothing is ever free - so we need to ask, who is paying the fee for the medicine/administration/consumables(plasters,sterets etc)/heat/light/staff/building etc...?
If something is necessary for employment purposes then in my view the employer should pay - by way of a fuller explanation.....
51 years ago the NHS decided to adopt a model of independent contractors status for general practice which for the majority of us has not changed IE As a GP I am a self employed businessman -GPs do not work for the NHS -
they have contracts with Health Authorities to provide services which may or may not be their only contracts
My main contract is with the health authority to provide "general medical services" for which I receive a capitation payment(and immunisations is not covered in GMS) - in addition there are Items of Service fees for a variety of other activities (lumps and bumps removal, contraceptive services,temporary resident advice....) which augment my gross income from this contract
In return I run the business ( and therefore have gross expenses) , employ 15 people (and thereby have to keep up with all the responsibilities of an employer as well as doctoring) and own the building in which this "NHS" activity takes place thereby taking responsibility literally for the loo roll to the tiles on the roof
So you will see that with this background it is not surprising that many GPs get irritated with "dumping" of work from employers or secondary care without a fee attached or promise of a suitable contract of terms for the work
> What happens at your practice?
For the odd patient on my NHS list who requests it I do give a course (and am happy with the small profit I make on buying bulk jabs and the amount the NHS reimburse for dispensing). For employees of the small companies I look after (inc a sewer diving firm) I charge 35 ukp per jab for Hep B
Any concerted effort by a company/NHS trust to have there employees immunised systematically by sending them to me( coz its "free" on the NHS") without prior arrangement of terms would meet with a simple no accompanied by my terms of business
Sorry to sound so long winded but an awful lot of misunderstandings arise because of basic ignorance of how GPs get paid
If I worked in a different model (IE salaried/40-60 hours per week then I would be more than happy to fill those hours with immunisations, although I suspect that my new managers would take a different view ;-)
cheers
--
Dr Mark O'Connor
www.physician.org.uk/
Please note the new email address for the UK Health and Safety Executive is @hse.gsi.gov.uk.
The old address @hse.gov.uk is still valid.
|