COVID-19 vaccinations in the workplace
On 4 May 2021, the Government Security Centre (Rządowe Centrum Bezpieczeństwa – “RCB”) provided access to detailed information on how to organise the COVID-19 vaccination process in workplaces. Presented below is the procedure and requirements to be met to organise vaccinations in your workplace.
Requirements
According to the guidelines published by the RCB, both individual employers and groups of employers may organise vaccinations for their personnel, in cooperation with Medical Service Entities (MSEs). The main requirements to carry out the vaccination process are:
- establishing cooperation between the employer (or employers, e.g. in Special Economic Zones) and MSEs.
- registration of at least 300 people who want to get vaccinated
- the possibility to plan the time of vaccination – it should be maximum 5 days
Registration Form
The intent to carry out the process of vaccination in the workplace is expressed by filling in a form available from the website of the Government Security Centre. Sending the form denotes readiness to vaccinate personnel in cooperation with the MSE indicated in the form. Thus, filling in the form should be made after agreeing the conditions of vaccination with the MSE and after obtaining employees’ statements confirming that there will be at least 300 people wanting to take the vaccine. At this stage it is not required to sign a vaccination agreement with the MSE. It is worth emphasizing that the MSE must be one of the existing points of COVID-19 vaccination under the National Vaccination Programme.
The form should include the personal details and the position of the person assigned the task of coordination of the vaccination process in the workplace. Additionally, it is necessary to provide information about the MSE cooperating with the employer (or group of employers). Cooperation with more than one MSE is permitted.
Who can get vaccinated?
Employers may register their employees and persons cooperating with them under civil-law agreements (including on a B2B basis), temporary workers and members of families of all those mentioned. Moreover, the registration form should specify the number of people willing to be vaccinated, but their personal data should not be included.
According to the information provided by the RCB, the lower limit of the persons who will eventually be vaccinated was not specified. Therefore, if some employees eventually resign from getting the vaccine in the workplace (e.g. they get vaccinated elsewhere or they do not qualify for vaccination), and the number of persons wanting to be vaccinated drops below 300, the remaining persons will still get vaccinated. However, in this situation, the number of vaccines ordered by the leading MSE should be reduced.
Requirements for vaccination
If vaccinations are to be made in the workplace, the employer is obliged, in cooperation with the MSE, to provide the required safe conditions. Sanitary requirements in this respect are presented in the Guidelines, in the section “Minimum Requirements of the Chief Sanitary Inspector and the Ministry of Health”. The information about the intent to carry out vaccinations outside a healthcare centre should be submitted to the National Health Fund. However, the FAQ do not indicate whether this is the responsibility of the employer or the MSE.
After staff vaccinations, the employer is also responsible for covering additional costs, if any, of organsing the vaccination process. Such costs may include, e.g. rental of rooms in which the vaccinations are to be administered.
The sequence of vaccinations depends on the time of submitting the form and availability of vaccines. When the time comes for the workplace, the Government Agency of Strategic Reserves will issue an offer to the MSE identified in the registration form, and the offer should be accepted within a week of its receipt. At this stage, the MSE may ask for a change of the offer, e.g. because some employees have already got vaccinated elsewhere. After the offer is accepted, the vaccines will be provided to the MSE, which will carry out the vaccination process in the workplace.
Should you have any questions in this respect, you are welcome to contact our experts.
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