What immunisations do my staff need?

Why it is required

There is no single law that lists staff vaccines. The duty comes from several places:

• the Health and Safety at Work etc. Act 1974, which requires employers to protect staff and others affected by their work
• COSHH, which treats pathogens as biological agents and requires employers to assess and control exposure to them. See COSHH for private GPs.
• in England, CQC regulations 12, 18 and 19, covering safe care, staffing and fit and proper persons employed.

The CQC's guidance for GP practices says you must make sure staff receive the immunisations appropriate for their role, and be able to show you have an effective employee immunisation programme. The detail comes from chapter 12 of the Green Book, Immunisation against infectious disease, published by the UK Health Security Agency.

What each role needs

Staff group	Routine	Selected vaccines
Clinical staff in direct patient care: GPs, nurses, healthcare assistants, phlebotomists	Tetanus, diphtheria, polio and MMR up to date	Hepatitis B if exposed to blood or body fluids. Varicella if susceptible. Annual flu. BCG only if in close contact with infectious TB patients.
Non-clinical staff with patient contact: receptionists, administrators, cleaners	Tetanus, diphtheria, polio and MMR up to date	Hepatitis B if at risk of sharps injury, bites or handling blood-stained items. Varicella if susceptible and in regular patient contact.
Staff who handle specimens	As above	Hepatitis B if they may have contact with blood or body fluids

Base the "selected vaccines" column on your COSHH risk assessment for each role. Chapter 12 says staff who are not at risk need not routinely be offered those vaccines.

Points to get right

• MMR. Satisfactory evidence is documentation of two doses of MMR, or positive antibody tests for measles and rubella. MMR matters because staff can pass measles or rubella to vulnerable patients.
• Hepatitis B. Check antibody levels one to four months after completing the primary course. The result guides what to do after a needlestick injury.
• Varicella. A definite history of chickenpox or shingles counts as protection. Staff with a negative or uncertain history should have a blood test, and only those without antibody should be vaccinated.
• Flu. The Green Book recommends annual flu vaccination for staff directly involved in patient care. The CQC also expects you to offer it.
• COVID-19. The CQC asks practices to encourage staff to have COVID-19 vaccination in line with current government guidance and chapter 14a of the Green Book, which changes over time.

The Green Book chapter is the source to follow for the detail. Check the current version before you set your policy.

Who pays

Chapter 12 says employers need to be able to demonstrate an effective employee immunisation programme and have an obligation to arrange and pay for it. It recommends that programmes are managed by occupational health services with appropriately qualified specialists.

Vaccines for occupational health must be bought privately, from manufacturers, pharmacies or wholesalers. Chapter 3 of the Green Book says centrally purchased NHS vaccine cannot be used for occupational health, with narrow exceptions, although it can be used to complete a routine course that is found to be incomplete. See ordering private immunisations.

For self-employed clinicians, such as sessional GPs, agree in writing who is responsible. As a provider you still need evidence that everyone working in your service is appropriately protected.

How to run it

1. Pre-employment health assessment. The CQC and the Green Book expect every new employee to have one, including a review of their immunisation needs. Use an occupational health provider, or a competent clinician who is not the employee's own GP.
2. Collect evidence. Ask for vaccination records and antibody results. Arrange missing doses or blood tests.
3. Record it. Keep a staff immunisation log with dates, results and review dates, stored securely as health data under UK GDPR.
4. Risk assess gaps. If a staff member does not have a required immunisation, the CQC says you must record a clear rationale and a risk assessment. Staff with underlying medical conditions should have a personalised assessment.
5. Review each year. Update the log for flu season, new starters and role changes.

Be careful with how you ask. Health information collected at recruitment must meet the Equality Act 2010 rules on pre-employment health questions, which generally means asking about health only after offering the job, unless an exception applies.

Scotland, Wales and Northern Ireland

The Green Book applies across the UK, so the recommendations are the same. The regulator differs: check the standards of Healthcare Improvement Scotland, Healthcare Inspectorate Wales or RQIA for what they expect to see. Northern Ireland has its own health and safety legislation, enforced by HSENI.