24 febbraio 2021 – Il caso è partito in questi giorni da quindici infermieri del Policlinico San Martino di Genova, ai quali, dopo essersi rifiutati di sottoporsi a vaccinazione contro il Covid-19 ed aver contratto il virus, la direzione Sanitaria avrebbe negato di riconoscere la condizione di infortunio sul lavoro e le conseguenti tutele INAIL, arrivando ad ipotizzare che per 593 sui 3.120 infermieri della struttura sanitaria che hanno scelto di non vaccinarsi si possa disporre una inidoneità al contatto con i pazienti, prevedendo che rimangano in smart working, oppure, se si tratta di personale sanitario, affidandogli le mansioni che non lo obblighi ad entrare in contatto con pazienti contagiati od addirittura arrivare all’aspettativa obbligatoria e non retribuita del lavoratore.
Ma se il vaccino Covid-19 non è obbligatorio, è possibile far derivare limitazioni ai diritti del lavoratore a causa di un suo dissenso, legato ad una libera scelta (cd. no-vax) o peggio per ragioni sanitarie (es. allergia o stato di gravidanza)?
D’altronde la questione è significativa e di estrema importanza, in quanto oltre al riconoscimento delle indennità economica ed assistenza sanitaria a carico dell’INAIL, il Coronavirus può portare a periodi anche molto prolungati di assenza dal posto di lavoro, con ogni conseguenza sul conteggio dei giorni di malattia per la conservazione obbligatoria del posto di lavoro (cd. periodo di comporto) che invece non vengono considerati nel caso di infortunio lavorativo.
È evidente che nella vicenda si scontrano interessi e norme giuridiche contrapposte: da una parte c’è l’obbligo del datore di lavoro di tutelare la salute del lavoratore (art. 2087 del codice civile) e di mettere a disposizione degli operatori sanitari quei dispositivi di protezione individuale, presidi ambientali e sistemi antinfortunistici idonei a scongiurare il rischio di contrarre il virus (D.lgsl. 81/2008), e sul fronte opposto l’art. 32 della Costituzione secondo il quale nessuno può essere sottoposto ad un trattamento sanitario se non per disposizione di legge.
Ed una legge sull’obbligo di vaccinazione, a carico degli operatori sanitari come per nessun altro, allo stato attuale non c’è.
Il quesito è stato rivolto all’INAIL, che a livello centrale ha finora mostrato una certa resistenza a riconoscere l’infortunio e le relative indennità per la contrazione del Coronavirus di medici ed operatori sanitari, anche se una sua circolare del marzo 2020 stabilisce una presunzione semplice di origine professionale del contagio per la categoria di lavoratori a rischio specifico Covid-19, dalla quale deriva l’accesso diretto ed obbligatorio alle tutele derivanti da infortunio sul lavoro.
È vero anche che l’art. 279 T.U. sulla salute prevede che il datore di lavoro debba mettere a disposizione dei vaccini efficaci per l’agente biologico “presente nella lavorazione”, ma ci sembra davvero discutibile poter affermare che il Coronavirus, stante la sua diffusione pandemica ed estesa ad ogni ambiente e soggetto, sia un rischio “tipico” delle professioni sanitarie e presente nel ciclo “produttivo” sanitario, quanto, piuttosto un rischio sociale che riguarda quindi ogni cittadino, che sia un infermiere o meno, con la conseguenza che la differenziazione sta solo nel livello dei dispositivi di protezione individuali ed ambientali messi a disposizione dal datore di lavoro, che devono essere in ogni caso efficaci e sicuri in base al tipo specifico di attività svolta.
E fino a che punto è possibile considerare il vaccino un dispositivo di protezione individuale? Trattandosi invece di un vero e proprio trattamento sanitario, oltretutto non obbligatorio per legge, la risposta da dare è sicuramente negativa.
Manca infine un sufficiente supporto della letteratura scientifica che dimostri l’efficacia dei vaccini come copertura al 100% dal rischio, e l’assenza di effetti collaterali apprezzabili, affinché si possa considerare il legittimo rifiuto del lavoratore come un comportamento abnorme e negligente dal quale far derivare un concorso di colpa del dipendente ed il rifiuto al risarcimento.
In conclusione se un lavoratore rifiuta di sottoporsi alla vaccinazione per il Covid-19, il datore di lavoro non potrà imporglielo né pregiudicarlo in qualche modo, ma dovrà al contrario coinvolgere il medico competente per eseguire un’analisi delle ragioni del dissenso (volontarie o sanitarie), la valutazione del rischio in base alla tipologia di attività svolta, le persone frequentate e l’ambiente di lavoro durante la prestazione, ed adottare tutte le precauzioni necessarie per evitare che contragga la malattia.
E per quegli infermieri e medici che sono stati mandati in prima linea nonostante avessero rifiu-tato la copertura vaccinale Covid-19, l’INAIL dovrà senza alcun dubbio aprire infortunio, provvedendo senza ritardo all’erogazione di tutti i benefici e le tutele previste per legge.
Avv. Massimiliano Gabrielli
Legale ANMIL
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