The Beacon Hospital did not consider giving leftover vaccines to higher priority groups before a group of private school teachers.
A HSE review believes it would have been feasible to give the jabs to others instead.
As part of Ireland's vaccination rollout - certain groups were prioritised, including healthcare workers and the elderly.
It would then proceed based on people's age.
However, controversy arose in the early stages of the rollout when 20 teachers from St gerards in Bray were given vaccines at the Beacon Hospital.
CEO Michael Cullen, whose children attended the school, called the headmistress to offer the jabs.
The HSE review has found no evidence that St Gerard's had solicited for the jabs prior to the offer.
The hospital insists this was done to avoid wastage.
The review says the Beacon moved by mobilising a group of people that they considered offered a viable solution to wastage.
However, this was done without considering alternative people or groups higher on the vaccine allocation groupings.
The HSE reviewer believes it would have been feasible to give the surplus vaccines to groups higher on the sequencing list had such a consideration been made.
