As a first step, licensees should review the records of personnel who are employed or engaged by them to ascertain if they fall within the scope of any of the exemptions in the licensing conditions.

In respect of other personnel that are not employed or engaged by them (such as external vendors), licensees should take appropriate steps to satisfy themselves that the exemption criteria are met. For example, one possibility would be for the licensees to include the immunity requirements and requirements for proof in relation to exemptions in their contracts with vendors. Licensees may also wish to establish an agreement with the vendors to allow licensees to access relevant records of immunity of such personnel upon request.

The intent behind the immunity requirements is to ensure that personnel are not a conduit of spread of diseases to patients (and healthcare workers) in the healthcare setting. Personnel whose work does not involve direct interaction with patients and who do not work within any premises of a healthcare institution which provides services that involve direct interaction with patients do not have to meet the immunity requirement. To illustrate, personnel who work in a testing laboratory would not have to meet the immunity requirements, if the laboratory is not located within the physical site of a healthcare institution which provides services involving direct interaction with patients (such as hospitals and clinics). If, however, the laboratory is located within the physical site of such a healthcare institution, it would be considered to be within its premises, and the immunity requirement would apply for the laboratory’s personnel.

In addition, personnel who are clinically not suitable for the vaccination (i.e., they have been certified permanently medically unfit for vaccination) also do not have to meet the immunity requirement.