Background

Vaccination against COVID-19 disease in Australia is currently recommended for all individuals aged 12 years and over. Due to the potential for high levels of disease transmission and an increased risk of severe disease in vulnerable groups, COVID-19 vaccination has been made mandatory for specific workplaces/industries within Victoria. Mandating is generally considered a late step in optimising vaccine uptake, as it is important to ensure vaccine access is available in an equitable way, before progressing to a mandate.

A mandate means that certain workers will be required to demonstrate proof of COVID-19 vaccination or provide an authorised medical exemption. Employers are responsible for ensuring that their workers comply with the Order. It should be noted that these orders or directions come from the Chief Health Officer in each jurisdiction, hence there may be some variations around Australia and this document is specific to Victoria.

Prior to COVID-19, vaccine mandates had been applied in a number of settings across Australia. For example, the ‘no jab, no play’ policy came into effect in Victoria in 2016, requiring all children to be fully vaccinated in order to enrol in childcare or early childhood education services. In 2018, national legislation (no jab, no pay) was introduced altering the eligibility for access to childcare subsidies and Family Tax Benefit Part A payments.

COVID-19 Mandatory Vaccination Directions

In September 2021, COVID-19 Mandatory Vaccination Directions were introduced in Victoria for the below workplace industries.

  • residential aged care facilities
  • construction sites
  • healthcare facilities
  • school, childcare and early learning
  • all other authorised workers (to continue working onsite).

For further information on the workers this Order applies to, please refer to Information for workers required to be vaccinated.

Responsibility of the employer

The employer or workplace industry is required to sight and store evidence of staff COVID-19 vaccination status. This includes evidence of:

  • full COVID-19 vaccination (dose 1 and 2); or
  • partial COVID-19 vaccination (dose 1 only) with a booking to receive dose 2 (by a specified date); or
  • booking to receive COVID-19 vaccines by a specified date (if unvaccinated); or
  • medical exemption (official documentation completed by an approved medical practitioner based on select criteria).

Responsibility of the employee

It is the responsibility of the employee to be vaccinated against COVID-19 or have a valid medical exemption. Vaccination for Victorian workers must be completed by the below dates.

Industry Date dose 1 must be received by Date dose 2 must be received by
Residential aged care 1st October, 2021 15th November, 2021
Construction 2nd October, 2021
Healthcare 29th October, 2021 15th December, 2021
School, childcare and early learning 25th October, 2021 15th December, 2021
Other authorised workers 15th October, 2021 26th November, 2021

Medical exemptions for COVID-19 vaccines

The only two absolute contraindications to vaccination are anaphylaxis to a previous dose of the same vaccine or anaphylaxis to a component of the vaccine.

There is also a small group of specific medical conditions listed (see below) for each COVID-19 vaccine brand, precluding some individuals from receiving that brand. These individuals can still receive vaccination with alternate vaccine platforms.

Medical contraindication
Comirnaty (Pfizer) Spikevax (Moderna) Vaxzevria (AstraZeneca)
  • History of anaphylaxis to a previous dose or to an ingredient of an mRNA COVID-19 vaccine
  • History of myocarditis attributed to a previous dose
  • History of anaphylaxis to a previous dose or to an ingredient of an mRNA COVID-19 vaccine
  • History of myocarditis attributed to a previous dose
  • History of anaphylaxis to a previous dose or to an ingredient of Vaxzevria
  • History of capillary leak syndrome, Cerebral venous sinus thrombosis (CVST), heparin-induced thrombocytopenia (HIT), idiopathic splanchnic (mesenteric, portal or splenic vein) thrombosis, antiphospholipid syndrome (with thrombosis and/or miscarriage)

Individuals who have experienced/at higher risk of experiencing a serious adverse event following a COVID-19 vaccines should be referred to VicSIS for review and management of COVID-19 vaccination. Individuals who have experienced a previous adverse event following COVID-19 vaccination should also be reported to SAEFVIC.

A medical exemption can only be approved by the below list of authorised practitioners and will be recorded on the individuals Immunisation History Statement on the Australian Immunisation Register.

  • a general practice registrar on an approved 3GA training placement; or
  • a public health physician; or
  • a general physician; or
  • an infectious disease physician; or
  • a clinical immunologist; or
  • a gynaecologist; or
  • an obstetrician; or
  • a general practitioner who is vocationally registered; or
  • a general practitioner who is a fellow of the Royal Australian College of General Practitioners (RACGP); or
  • a general practitioner who is a fellow of the Australian College of Rural and Remote Medicine (ACRRM).

Clinician guidance on how to approach discussions relating to medical exemptions can be found via the Discussion guide for medical exemptions document.

Temporary medical exemption

The Australian Immunisation Registration (AIR) immunisation medical exemption form also includes temporary exemptions. Temporary medical exemptions can only be recorded for up to 6 months. If the cause of the medical contraindication persists, a new medical exemption form will need to be completed.

Please note: Exemptions completed via this form are currently experiencing delays in being reflected on the AIR. For immediate reflection on AIR it is recommended that exemptions are recorded via PRODA. For guidance on how to do this please refer to: How to record a medical contraindication on the AIR using HPOS.

The Australian Technical Advisory Group on Immunisation (ATAGI) has also provided clinical guidance on how to use this form.

Resources

Authors: Angela Berkhout (MVEC Immunisation Fellow), Nigel Crawford (Director, SAEFVIC, Murdoch Children’s Research Institute), Jim Buttery (Head of Health Informatics, Epidemiology and Signal Detection, SAEFVIC), Rachael McGuire (MVEC Education Nurse Coordinator) and Francesca Machingaifa (MVEC Education Nurse Coordinator)

Date: October 2021

Materials in this section are updated as new information and vaccines become available. The Melbourne Vaccine Education Centre (MVEC) staff regularly reviews materials for accuracy.

You should not consider the information in this site to be specific, professional medical advice for your personal health or for your family’s personal health. For medical concerns, including decisions about vaccinations, medications and other treatments, you should always consult a healthcare professional.