Risk-based workforce immunisation programs in dental settings require clarification for both dental practices implementing the NSQHS Standards and for accrediting agencies assessing the NSQHS Standards.

Public hospitals, some public dental practices and other health service organisations that vaccinate members of the workforce through internal processes need to comply with the National Health and Medical Research Centre’s (NHMRC) Guidelines 2010. However, the need for vaccination processes and record keeping requirements do not apply to health service organisations that do not vaccinate internally (such as private dental practices).

Action 3.6.1 requires dental practices implementing the NSQHS Standards to have in place a workforce immunisation program that complies with current national guidelines. However, NHMRC Guidelines 2010 does not say how practices should put workforce immunisation programs in place.
Dental practices implementing Action 3.6.1 should consider information and regulation from their jurisdictional health department in regard to local workforce immunisation requirements.

The Standard requires a risk-based workforce immunisation program. However, members of the workforce may choose not to be vaccinated.


A dental practice that is addressing its infection risks will have a workforce immunisation program in place. This program will identify and manage the risks associated with vaccine preventable diseases and infections for its workforce and patients.

A workforce immunisation program that meets the requirements of Action 3.6.1 will include:

• a record of the immunisation status for each member of the workforce, including evidence of immunisation where it is available
• a policy based on the NHMRC’s Australian Immunisation Handbook and local jurisdictional requirements
• a statement of the risks and how these risks are to be managed
• detail of the information provided to the workforce about:
– immunisation and relevant vaccine preventable diseases
– how the dental practice manages vaccine refusal (for example, how it will manage the risk of a member of the workforce transmitting disease to vulnerable patients)
– what will happen if a member of the workforce chooses not to be immunised following reasonable requests for immunisation
• reference to infection prevention and control practices
• information on the process for reviewing and maintaining the workforce immunisation program
• a record of:
– advice provided to the workforce
– members of the workforce that refuse requests to be vaccinated.

Dental practices may use their workforce immunisation register as evidence of compliance with Action 3.6.1. A workforce immunisation register may be as simple as:

1. information on all members of the workforce employed by the dental practice
2. the date that each member of the workforce commenced employment with the dental practice
3. the immunisation status of each member of the workforce
4. whether or not a letter from a qualified health care professional is held on file for each member of the workforce, stating they have been immunised as required for the type of work they do, in accordance with the recommendations of the Australian Immunisation Handbook (and jurisdictional requirements where relevant). It is anticipated that letters would be dated and include the details of the issuing health professional or organisation (doctor, clinic or hospital).

A dental practice should manage its risks by using standard precautions. Particular attention should be placed on personal protective equipment and barrier controls for the workforce with a higher risk of exposure. Workforce training can also be a way of reducing the risk of infection.

Additional strategies may need to be developed and applied to address one-off or higher risk situations. This may include dental practices choosing to re-schedule the patient until they are non-infectious when it is known they have a vaccine preventable disease.

A dental practice must assess and manage the risk of non-immunised members of the workforce working where there is a risk of infection being transferred. The risk assessment and management plan should be documented as evidence that Action 3.6.1 has been met. Where a dental practice has non-immunised members of the workforce, the responsibility for managing risk rests with the practice. However, it should be noted that under the Work Health and Safety Act 2011, both members of the workforce and employers have duties of care to fulfil.