ANA Raises Concerns About Smallpox Immunization

Letter to Health & Human Services Secretary Tommy Thompson

November 7, 2002

The Honorable Tommy G. Thompson
Secretary of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201

Dear Secretary Thompson:

The American Nurses Association (ANA) applauds your leadership and the leadership of others in the Department of Health and Human Services in planning and preparing the U.S. health care system and health care providers to respond to the potential use of a weapon of mass destruction. Since 1998, the ANA has also been involved in developing strategies for educating the nation's 2.7 million registered nurses to respond to such an event. As the largest professional association representing registered nurses, ANA is very interested in the current discussion within the Administration on the proposal to vaccinate 500,000 health care workers against smallpox in a pre-event scenario.

In light of the recent recommendations from the Advisory Committee on Immunization Practices (ACIP), ANA identifies the following issues for your consideration as the Administration continues its deliberations.

Considerations related to Vaccinating Health Care Workers

• The decision by a health care worker on whether to be vaccinated should be made voluntarily and without fear of reprisal. This decision should be based on complete information regarding the potential risks associated with the vaccine.

• Costs related to vaccination and possible treatment for any side-effects, including potential side-effects suffered by family members, must be considered. These costs should not be incurred at the expense of the health care worker nor should delay for coverage be an expectation. An additional concern is that, at the present time, the Vaccine Injury Compensation Program (VICP) does not cover voluntary immunizations.

• Time-off associated with the vaccination process should not be charged to the health care workers' sick or vacation time and should be considered paid time. In addition, any furlough time required post-vaccination should also be considered paid time. Also, hospitals and health systems should develop alternative staffing plans to ensure sufficient staff coverage in any facility that initiates a health care worker vaccination policy.

• Risk of complications associated with skin diseases or dermatitis is of particular concern to ANA. It is estimated that 8-12 percent of health care workers are sensitized to latex that often presents itself in the form of dermatitis. In general, health care workers have a history of dermatitis as a result of hand washing, wearing gloves, and coming into contact with harsh agents and detergents. The potential for dermatologic reactions must be taken into account both in discussing the overall vaccination policy and when developing the screening questionnaire and interview process.

• Furlough of vaccinated providers to prevent the risk of a provider to patient transmission appears to be a point of disagreement in the research community. While there is only one known case of a provider to patient transmission during the prior vaccination period, today's patient population is dramatically different from that of the 1960s and early ‘70s. The hospital patient of today is more acutely ill and health compromised than before. Additionally, it is unclear if the use of an occlusive dressing would be sufficient protection against transmission to a patient.

• To counteract adverse reactions, even in the absence of additional information regarding its effectiveness or alternative treatments, sufficient doses of Vaccinia Immune Globulin (VIG) should be readily available.

• Finally, a comprehensive surveillance plan should be in place to monitor and evaluate all persons who are vaccinated.

Considerations related to Health Care Workers Administering the Vaccine

• There needs to be discussion related to the potential liability/malpractice concerns as a result of administration of the vaccine.

• ANA strongly supports the development and use of a vaccine administration system that will eliminate the potential for needlestick injuries to occur and is in accordance with the provision of the 2000 Needlestick Safety and Prevention Act.

The American Nurses Association strongly believes registered nurses should be prepared to respond should another terrorist event occur, particularly one using a biological agent. As you know, ANA already is working closely with the Department to develop the National Nurses Response Team for just such an event.

ANA also recognizes that the policy questions under consideration are significant and require timely action. However, the questions and concerns that we have outlined are likely to be raised by health care workers and will need to be addressed. Successful implementation of a vaccination policy depends on thoughtful resolution of these and other issues that may be raised by frontline health care providers. ANA stands ready to assist the Administration in addressing these concerns.

I would be pleased to talk with you further about ANA's concerns. I can be reached at 202-651-7011 or you may contact ANA Senior Policy Fellow Cheryl Peterson at 202-651-7089.

Sincerely,

Barbara A. Blakeney, MS, APRN,BC, ANP
President

 

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