Anvil Clinical Hygiene Vaccination Policy Guide

Clinical Hygiene, Employee Health, Vaccination Policy

This Employee Vaccination Policy outlines Anvil Clinical Hygiene’s standards and expectations for required immunizations, masking, and documentation for employees working in clinical hygiene and commercial cleaning roles serving medical offices, clinics, and healthcare facilities throughout Washington State.

Protecting Patients Through Employee Vaccination

Anvil Clinical Hygiene’s standards for safe clinical environments

Purpose and Scope

The purpose of this vaccination policy is to protect the health and safety of patients, clinical staff, Anvil Clinical Hygiene employees, and visitors in the medical environments we serve. As a clinical hygiene and commercial cleaning provider operating in Washington State, Anvil Clinical Hygiene (“the Company”) maintains strict infection prevention standards that align with industry best practices and support our clients’ regulatory and accreditation requirements. A comprehensive vaccination policy is a critical component of these standards and of our broader commitment to employee health and clinical hygiene excellence.

This policy applies to all employees of Anvil Clinical Hygiene, including but not limited to:

• Field staff providing clinical hygiene or commercial cleaning services at client medical offices, clinics, and healthcare facilities in Washington State
• Supervisors, managers, and quality assurance personnel who enter client care areas or clinical spaces as part of their duties
• Any other employees whose roles require them to be physically present in client facilities or to engage in client-facing work

Administrative and remote staff who do not enter client facilities on Company business are not required to comply with all provisions of this policy; however, they may be subject to vaccination or masking requirements when visiting client sites, attending in-person Company meetings, or as otherwise specified by management or client contracts. Where client-specific standards exceed the requirements in this policy, Anvil Clinical Hygiene employees must comply with the more stringent standard as a condition of assignment at that site.

Required Vaccinations

1. Hepatitis B Vaccination (Highest Priority Requirement)

Hepatitis B (“Hepatitis B” or “Hep B”) vaccination is the highest-priority immunization requirement for Anvil Clinical Hygiene field staff. Due to the nature of clinical hygiene and commercial cleaning services in medical environments, employees may be exposed to blood or other potentially infectious materials. To reduce the risk of occupational exposure to Hepatitis B virus (HBV), the following standards apply:

• All field staff assigned to clinical environments must either have completed the full Hepatitis B vaccine series or be actively in the process of completing the series before performing work in patient care or clinical areas.
• The standard Hepatitis B vaccine series generally consists of three (3) doses over a defined schedule. Employees must follow the schedule recommended by their healthcare provider and applicable public health guidance.
• Proof of prior completed Hepatitis B vaccination series, or documentation of immunity (e.g., a positive Hepatitis B surface antibody titer), may be accepted in place of a new series, subject to review by Human Resources.
• New hires must submit documentation of Hepatitis B vaccination status as part of the onboarding process. Employees who have not yet completed the series may be approved to begin client assignments only if they have received at least the first dose and have scheduled subsequent doses as appropriate.

Employees who decline Hepatitis B vaccination for medical or religious reasons must follow the procedures outlined in the Exemptions and Accommodations section of this policy and are subject to the Masking Requirement for Unvaccinated Employees described below. In addition, certain client facilities may prohibit unvaccinated personnel from entering specific areas or performing certain tasks; Anvil Clinical Hygiene will comply with all such client requirements, which may limit available assignments for unvaccinated employees.

2. Influenza (Flu) Vaccination – Annual Requirement

Seasonal influenza presents a significant risk to patients, healthcare staff, and visitors in clinical settings. To minimize the spread of influenza and support our clients’ infection prevention programs, Anvil Clinical Hygiene requires an up-to-date annual flu vaccine for all client-facing staff and employees who enter clinical environments during flu season, unless a documented exemption has been approved in accordance with this policy.

• The annual flu vaccine must be obtained prior to the onset of each flu season, generally by a date specified by Anvil Clinical Hygiene in alignment with Washington State public health guidance and client facility requirements (typically by early fall each year).
• Employees are responsible for obtaining the current-year influenza vaccination from a licensed provider, pharmacy, clinic, or other authorized source, unless otherwise arranged by the Company or client facility.
• Documentation of the flu vaccine (such as a vaccination card, clinic record, or employer-provided proof) must be submitted to Human Resources by the deadline communicated each year.

Employees who fail to provide proof of the current-season flu vaccine and who do not have an approved exemption may be temporarily removed from client-facing assignments until they achieve compliance. Those with approved medical or religious exemptions must comply with the continuous masking requirements and any additional precautions required by specific client sites during flu season.

3. COVID-19 Vaccination – Strongly Required for Client-Facing Staff

COVID-19 continues to be a significant public health concern, particularly in healthcare environments and among vulnerable patient populations. To support safe operations and align with the expectations of our healthcare clients in Washington State, Anvil Clinical Hygiene strongly requires up-to-date COVID-19 vaccination for all client-facing employees and staff entering clinical facilities, subject to applicable law and legitimate medical or religious exemptions.

• “Up-to-date” COVID-19 vaccination generally means completion of an initial vaccine series and any booster doses recommended by public health authorities for the employee’s age and risk group, as may be updated over time.
• Employees are expected to follow current Centers for Disease Control and Prevention (CDC), Washington State Department of Health, and client facility guidance regarding recommended COVID-19 vaccines and boosters for healthcare-associated workers.
• Proof of COVID-19 vaccination status must be submitted to Human Resources and may be shared with client facilities upon request, consistent with privacy and confidentiality requirements.

While COVID-19 vaccination is characterized as “strongly required” rather than absolutely mandatory, employees who decline COVID-19 vaccination without an approved exemption may face limitations on assignments, particularly where client facilities mandate vaccination for onsite personnel. All employees who are not fully vaccinated against COVID-19, whether due to personal choice, medical reasons, or religious belief, must comply with the Masking Requirement for Unvaccinated Employees and any additional infection control measures required by specific clients or by public health authorities.

Exemptions and Accommodations (Medical and Religious)

Anvil Clinical Hygiene recognizes that some employees may be unable to receive certain vaccinations, or may decline them, due to legitimate medical conditions or sincerely held religious beliefs. In accordance with applicable federal, state, and local laws, including laws in Washington State, the Company will consider requests for exemptions from the Hepatitis B, flu vaccine, and COVID-19 vaccination requirements on an individual basis and will provide reasonable accommodations where feasible and where they do not create an undue hardship or compromise patient and workplace safety.

Medical Exemptions

Employees seeking a medical exemption from any required vaccination must submit a written request to Human Resources accompanied by documentation from a licensed healthcare provider. The documentation must clearly state that the employee has a medical condition or contraindication that prevents them from safely receiving the specific vaccine(s) and should indicate whether the exemption is temporary or permanent. The Company may request additional information, consistent with applicable law, to evaluate the request and determine appropriate accommodations.

Religious Exemptions

Employees requesting an exemption on the basis of sincerely held religious beliefs must submit a written statement to Human Resources explaining the nature of the belief and how it conflicts with the vaccination requirement. The Company may request additional information as permitted by law to assess the sincerity and scope of the belief and to determine whether a reasonable accommodation can be provided while maintaining safe operations in clinical environments.

Accommodation Process and Limitations

All exemption requests will be reviewed on a case-by-case basis by Human Resources, in consultation with management and, where appropriate, with legal or occupational health advisors. Approved exemptions may result in accommodations such as:

• Mandatory and continuous use of a properly fitted mask and other personal protective equipment (PPE) while on duty at client facilities
• Reassignment to non-clinical or lower-risk areas, where operationally feasible and consistent with client contracts
• Scheduling adjustments to limit exposure in high-risk environments, as appropriate and practical

An exemption from vaccination does not guarantee a specific accommodation or continued eligibility for all assignments. Some client facilities may require vaccination as a condition of entry and may not permit unvaccinated personnel onsite, even with masking. In such cases, Anvil Clinical Hygiene must comply with client policies, which may limit available work opportunities for unvaccinated employees, including those with approved exemptions. The Company will make reasonable efforts to identify alternative assignments where possible but cannot guarantee placement in all circumstances.

Masking Requirement for Unvaccinated Employees

To mitigate the risk of disease transmission in clinical and healthcare environments, Anvil Clinical Hygiene requires that any employee who declines or is unable to receive required vaccinations for medical or religious reasons must wear a properly fitted mask at all times while on duty at client facilities. This requirement applies to:

• Employees with approved medical or religious exemptions from Hepatitis B, influenza, or COVID-19 vaccines
• Employees who are partially vaccinated or in the process of completing a vaccine series and have not yet reached full vaccination status, as defined by public health guidance

For purposes of this policy, a “properly fitted mask” means a medical-grade mask or respirator (such as a surgical mask or, where required by the client, an N95 or equivalent) worn securely over the nose, mouth, and chin at all times while in client facilities, except when briefly removed in accordance with client site rules (for example, while eating or drinking in designated areas away from patient care spaces). Cloth masks or face coverings alone may not meet this requirement unless explicitly authorized by the Company and the client facility based on current public health guidance.

Employees subject to the masking requirement must comply strictly and consistently. Failure to wear a mask correctly and continuously in required areas will be treated as a violation of this policy and of client safety protocols, and may result in removal from the site and disciplinary action, up to and including termination of employment. Client facilities may impose additional PPE requirements, and employees must comply with the more stringent standard when there is any difference between Company policy and client rules.

Documentation and Proof of Vaccination

To ensure compliance with this vaccination policy and to meet client and regulatory expectations, Anvil Clinical Hygiene requires employees to provide timely and accurate documentation of their vaccination status. This includes, as applicable, Hepatitis B, annual flu vaccine, and COVID-19 vaccinations. Documentation may include:

• Official vaccination records from a healthcare provider, pharmacy, clinic, or public health agency
• Immunization cards indicating vaccine type, date(s) administered, and provider information
• Laboratory reports demonstrating immunity (e.g., Hepatitis B surface antibody titers), where applicable

Employees must submit proof of vaccination to Human Resources by the deadlines communicated for each vaccine requirement. Documentation will be maintained in secure, confidential files separate from general personnel records, and will be used solely for legitimate business purposes, including verifying compliance with Company policy, client contracts, and applicable laws and regulations. Vaccination information may be shared with client facilities when necessary to confirm eligibility for onsite work, consistent with privacy obligations.

Employees are responsible for promptly informing Human Resources of any changes to their vaccination status, including completion of additional doses, boosters, or new vaccine series. Providing false, altered, or misleading vaccination documentation is strictly prohibited and will result in disciplinary action, up to and including termination of employment, and may be reported to appropriate authorities where required by law.

Compliance and Consequences of Non-Compliance

Compliance with this vaccination policy is a condition of employment for employees whose roles require them to work in or enter client medical offices, clinics, and healthcare facilities. Adherence to vaccination, masking, documentation, and related requirements is essential to maintaining safe, high-quality clinical hygiene services and to upholding Anvil Clinical Hygiene’s contractual obligations to healthcare clients in Washington State. Failure to comply with this policy may result in one or more of the following actions, depending on the circumstances and severity of the violation:

• Removal from specific assignments or client facilities where vaccination or masking requirements are not met
• Temporary suspension from client-facing duties until the employee achieves compliance (e.g., receives required vaccines or submits valid documentation)
• Written warnings, performance improvement plans, or other corrective measures administered through the Company’s disciplinary process
• Termination of employment where non-compliance is willful, repeated, or incompatible with the essential functions of the employee’s position or with client requirements

Examples of non-compliance include, but are not limited to, failure to obtain or document required vaccines within specified timeframes, refusal to wear a properly fitted mask when required, falsification of vaccination records, or disregard of client facility infection control rules. Employees are encouraged to communicate proactively with Human Resources if they anticipate difficulty meeting a vaccination deadline or if they have questions about how this policy applies to their role. The Company will work in good faith to support employees in achieving compliance while prioritizing patient and workplace safety.

Effective Date, Review, and Policy Updates

This Employee Vaccination Policy for Anvil Clinical Hygiene is effective as of [Effective Date: __________________] and applies to all covered employees working in Washington State from that date forward. New hires will be informed of this policy during the recruitment and onboarding process, and continued employment in client-facing roles is contingent upon adherence to the requirements set forth herein, subject to approved exemptions and accommodations.

Because public health guidance, regulatory requirements, and client expectations may change over time, Anvil Clinical Hygiene reserves the right to modify, supplement, or rescind this policy, in whole or in part, at any time. Updates may include changes to the list of required vaccines, timelines, masking standards, or documentation processes, as well as the addition of new measures designed to protect employee health and safety. The Company will communicate any material changes to employees through appropriate channels, which may include written notices, email communications, policy postings, or updates on the Company intranet or blog.

Nothing in this policy is intended to conflict with applicable federal, state, or local laws or regulations. In the event of a conflict, Anvil Clinical Hygiene will follow the law and will interpret and apply this policy to be consistent with legal requirements in Washington State and any other jurisdiction in which the Company operates. Questions regarding this policy, including how it applies to specific positions or client sites, should be directed to Human Resources or to the employee’s manager.