Choosing the correct legal mechanism

Written instructions for intramuscular influenza vaccination administration are only for vaccination of staff as part of occupational health or peer-to-peer vaccination schemes.

The term “staff” in this article includes those offering commissioned services, sub-contracted staff, agency staff, individuals undertaking work placements with the organisation and volunteers.

For NHS vaccination of individuals within the national eligibility criteria for influenza vaccination please refer to the appropriate PGD/national protocol for the service:

• UKHSA Patient Group Direction template for inactivated influenza vaccine (requires local authorisation before use)
• NHSE National Protocol for inactivated influenza vaccine
• NHSE community pharmacy seasonal influenza vaccine service

Written instructions

Where vaccinations cannot be provided on a patient specific basis, the written instruction is the preferred way for OHS to be delivered.

Staff working under a written instruction

In 2022 a permanent amendment was made to Schedule 17 of the Human Medicines Regulations 2012 to allow occupational health vaccinators working within an NHS body or a Local Authority-operated occupational health scheme to administer influenza or coronavirus vaccines in accordance with a written instruction.

NHS body or Local Authority occupational health vaccinators

An occupational health vaccinator is a listed professional who is employed or engaged by a person operating an OHS.

The following professions can act as NHS body or Local Authority occupational health vaccinators:

• 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
• pharmacists

These occupational health vaccinators (except for registered nurses) cannot operate under an OHS written instruction for the supply or administration of any other medication (including other vaccines).

Occupational health vaccinators cannot operate within non-NHS/Local Authority provided services.

Independent and other organisations

Independent and other organisations may use a written instruction to administer influenza or coronavirus vaccines as part of an occupational health scheme but only registered nurses within these organisations can operate under a written instruction.

OHS commissioned from another provider

Where your organisation commissions its OHS from another provider but this doesn’t include provision of seasonal influenza vaccination to your staff, your organisation can still adopt the national written instruction template to offer staff peer-to-peer seasonal influenza vaccination.

The provision of seasonal influenza vaccination to staff can be offered as a separate operation to the commissioned OHS.

Therefore, peer-to-peer influenza vaccination can be undertaken by an organisation under the relevant written instruction once signed by an appropriate doctor in the organisation. Using written instructions in occupational health services contains further information.

Under the current legislation, for the purpose of the written instruction, peer-to-peer vaccination refers to the administration of the seasonal influenza or coronavirus vaccine by an appropriately trained and registered nurse (or for an NHS Body or Local Authority an occupational health vaccinator) to another employee of the same organisation.

Authorisation within organisations

Authorisation of written instructions within organisations requires the signature of an appropriate registered doctor before they can be used.

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. Where there is no such doctor employed or 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).

Use within organisations

Once signed and adopted, the written instruction allows named registered healthcare professionals included in the legislation to administer the seasonal influenza vaccination to the organisation’s staff, including peer-to-peer vaccinators. Vaccinators must be trained and competent to work in accordance with the written instruction.

Use of a written instruction to provide any other vaccination, immunisation or treatment to staff as part of an OHS should only be undertaken by the occupational health department providing these services to an organisation, whether that is in-house provision or as a commissioned service. These should be managed under the direction of an occupational health physician and any decision to use a written instruction made by them.

Adaptation of the influenza vaccination written instruction template to provide other vaccinations, immunisations or treatments to staff is not permitted. It is intended that only seasonal influenza (and potentially coronavirus) vaccination is delivered under a written instruction in this way due to its exceptional scope.

Managing staff with exclusions

Members of staff excluded from receiving the seasonal influenza vaccine under the written instruction should be referred to the occupational health consultant or their GP as appropriate. In the case of postponement due to acute illness, advise when the individual can be vaccinated and how future vaccination may be accessed. Document the reason for exclusion and any action taken in the individual’s occupational health records.

Using UKHSA/NHSE national PGDs and protocols

The UKHSA/NHSE PGDs and NHSE National Protocol for influenza vaccination can only be used for the vaccination of healthcare staff listed within the PGD/national protocol, reflecting those listed within the national eligibility criteria.

Refer to the relevant PGD/national protocol for influenza for further advice on which healthcare staff groups are included. Any healthcare staff groups not included cannot be vaccinated under the UKHSA/NHSE PGD/NHSE National Protocol.

Using PGDs in occupational health services (OHS) contains further information on the use of PGDs to provide influenza vaccinations via an OHS.

Doctors and dentists and peer-to-peer influenza vaccinations

For peer-to-peer influenza vaccinations, doctors and dentists may vaccinate their peers either by prescribing and administering the vaccine, or administering under the prescription of another prescriber. The process to be followed is for local agreement following governance considerations.

Training

Where a doctor or dentist is prescribing and administering an influenza vaccine and is not a specialist in occupational health, they should act within the same framework as other peer-to-peer vaccinators. They should complete the same training and declare themselves as competent and use the PGD or written instruction as guidance (i.e. inclusion and exclusion criteria). They should refer to an occupational health service (OHS) specialist any person who is excluded, as any other peer-to-peer vaccinator would be expected to.

Alternative options for access to vaccination

Organisations can pay for staff, who are not included in the national specification to receive an NHS funded vaccine, to receive vaccination (including seasonal influenza or travel vaccines required for work-related travel). Where employer provided OHS provision is not in place, they can do so via community pharmacies or vaccination providers who offer such services under private PGDs.

This is commonly carried out under a private voucher scheme and is not considered an occupational health service.

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