UPDATED OCTOBER 2020 to reflect legislation changes
Following advice issued in Spring 2018 advising on the use of Patient Group Directions in Occupational Health Services, SPS became aware of issues being encountered by healthcare organisations in offering employees the seasonal ‘flu vaccine, including peer to peer vaccination, within the legislation.
In late 2018 SPS began working with the CQC, MHRA, RCN, PHE, BMA Occupational Health Committee and representatives from NHS and independent sectors to identify a way that organisations can offer employee seasonal ‘flu vaccinations within the legislation.
The outcome of this work has been to produce written instructions for seasonal influenza vaccination.
In October 2020, The Human Medicines (Coronavirus and Influenza) (Amendment) Regulations 2020 provided an additional time limited (to 1 April 2022) amendment to Schedule 17 to allow occupational health vaccinators (that is registered nurses, registered midwives, registered nursing associates; operating department practitioners, paramedics or physiotherapists registered in Part 13, 8 or 9 of the Health and Care Professions Council register; and pharmacists, who are employed or engaged by a person operating an occupational health scheme) to administer influenza or coronavirus vaccines as part of an NHS Body or Local Authority (LA) occupational health scheme in accordance with the written directions of a doctor.
The written instruction can be adopted by organisations following the signed authorisation of the written instruction by an appropriate doctor. This medical signatory must be the doctor assuming responsibility for the delivery of the influenza vaccination programme to staff within an organisation; this should be an Occupational Health Physician employed by the organisation but where there is no such doctor employed/contracted by the organisation it should be the doctor assuming responsibility for the delivery of the influenza vaccination programme to staff within the organisation (for example the organisation’s Medical Director).
Once signed and adopted it allows named registered healthcare professionals* included in the legislation to administer the seasonal influenza vaccination to the organisation’s staff, including as a peer to peer vaccinator. Immunisers must be trained and competent to work in accordance with the written instruction.
*Note for an NHS Body or Local Authority the healthcare professional who can operate under a written instruction when engaged or employed as occupational health vaccinators are: nurses, midwives and nursing associates currently registered with the Nursing and Midwifery Council (NMC); operating department practitioners, paramedics and physiotherapists registered in Part 8,9 or 13 of the Health and Care Professions Council register; pharmacists registered with the General Pharmaceutical Council. For independent/other organisations only registered nurses can act under a written instruction.
A factsheet to support the use of the written instruction by organisations is available below alongside additional advice which is specific to GP practices. A written instruction template for OHS provision of seasonal ‘flu by registered nurses in available below. PLEASE NOTE a written instruction template for an NHS Body or a Local Authority, reflecting the additional occupational health vaccinator professions will be published on this page in early November 2020.
Further advice on the use of PGDs within Occupational Health Services is available via the link below.