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Radiation machine inspections ongoing in California during pandemic

Records of occupational exposure to radiation required

September 09, 2020 1163

Quick Summary:

Owners of radiological equipment must register each source of radiation with the California Department of Public Health Radiologic Health Branch. Dental offices are to be inspected at five-year intervals and must maintain records of occupational exposure to radiation.

Radiation machine inspections are following their typical schedules during the pandemic, and dental practice owners are reminded to ensure they are properly documenting occupational exposure to radiation and maintaining those records. 

Registration required annually, fees collected every two years

The owner of a dental practice’s radiological equipment must register each source of radiation with the California Department of Public Health Radiologic Health Branch. Vendors of the equipment do not register the equipment on behalf of the new equipment owner.

The state collects registration fees for each source of radiation every two years. The current fee for dental X-ray units is $118 per tube, per year; therefore, the equipment owner will pay two years’ worth of fees at the time of fee collection.

The radiation machine owner will use a specific registration form depending on whether 1) they are the owner of a new dental facility (through start-up or purchase), 2) they need to report a sale or purchase of an X-ray machine or a change of address or 3) they need to withdraw the X-ray facility registration – meaning the practice is closing and no longer possesses any previously registered machines or the machines are no longer functional. 

Dental radiation machines inspected every five years

All dental offices are to be inspected at five-year intervals and will receive a device to screen for exposure. The results of that exposure reading are compared to established standards, and the dental offices that return the screening devices that show the greatest deviation from the standards, along with those facilities that did not return the screening devices, will be scheduled for an on-site inspection.

RHB notes online in its COVID-19 guidance that to limit the time inspectors are physically in the facility, “the inspections will include remote inspection components.” 

The on-site inspector will evaluate compliance with radiation protection laws and regulations, take measurements (kVp, timer, exposure and filtration), evaluate processing and ensure radiation protection procedures are in place, such as posting of required documentation and a radiation protection plan. Six pieces of radiation-related documentation should be available in the dental practice.

Some offices that return screening devices that are within the normal exposure range may also be scheduled for inspection for routine quality assurance. Recent inspections have sought to verify that dental office staff has certificates or licenses required to take radiographs. Inspectors make recommendations to correct identified deficiencies and if applicable will issue a notice of violation that requires the dental office’s response.

Records of occupational exposure to radiation required

Dental practices must maintain records of occupational exposure to radiation and can collect that exposure data though one of two ways: The practice can either hire a health physicist to perform the calculations for the facility or have staff wear personnel monitoring devices, known as dosimeters, for a period adequate to calculate an annual dose. More information about the use of dosimeters, including in practices that utilize handheld portable dental X-ray systems, is available in CDA Practice Support’s 
Radiation Safety FAQ.

Also, when one or more employees work at other dental practices, the California Department of Public Health expects each employer to gather information on each employee’s radiation exposure at the other employer. CDA Practice Support offers an Employee Occupational Exposure to Radiation form that the dental employee can use to gather and log the required exposure information.

CDA members can access additional radiation-related resources in the Practice Support resource library. 

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