Current registrations and safety certificates required of X-ray machine owners, operators

With the recent increase in X-ray machine registration fees, CDA reminds members to ensure their registrations are up to date.

Under Title 17 of the California Code of Regulations, every person who acquires a radiation machine must register the machine with the California Department of Public Health’s Radiologic Health Branch within 30 days of acquiring the machine. Thereafter, the RHB typically bills dental practices biennially for X-ray machine registration fees. However, CDA Regulatory Compliance Analyst Teresa Pichay cites recent calls from dentists who were surprised to receive past-due bills for registration fees dating as far back as eight years, and she cautions dentists that “not receiving a bill does not exempt a facility with X-ray equipment from paying the registration fees.”

The registration fee increases were determined by the California Department of Finance and took effect Sept. 1, 2017. Practices should have received or can expect to receive bills for the new amounts for any payments due on or after this date. A table listing the new fees is available on the Radiologic Health Branch page of the CDPH website).

Radiation safety certificate requirements

The CDPH has been conducting compliance inspections of dental practices and has found instances of unlicensed dental assistants operating without appropriate radiation safety certificates. These cases have been forwarded to the Dental Board of California for further investigation.

Dentists and registered dental hygienists as well as registered dental assistants who completed an approved California dental assisting educational program after Jan. 1, 1985, may take radiographs in a dental practice.

Unlicensed dental assistants, in addition to RDAs and DDSs who did not complete a dental board-approved educational program after Jan. 1, 1985, must complete and pass a radiation safety course approved by the dental board prior to taking radiographs in a dental practice. The course must be a minimum length of 32 hours with at least 12 laboratory hours and include theory and clinical application. A list of board-approved courses is available on the dental board’s website.

Jan. 10 update: CDA has learned that dental assistants are using a completed DANB course in radiation safety to satisfy California’s radiation safety course requirement. They should be advised that DANB is not a California Dental Board-approved course provider.

Find X-ray machine registration fees and forms on the Department of Public Health’s website. For more background on the fee increases, see the related CDA article.

Related Items

Radiologic Health Branch fees are due to increase 26.76 percent Sept. 1, 2017, under the Budget Act of 2016, Chapter 23, in accordance with California Health and Safety Code section 100425. Five fee types are increasing, including registration of reportable sources of radiation renewal and certification in radiologic technology or nuclear medicine technology application.

Well ahead of the compliance deadline, CDA has updated its Proposition 65 resources to include the dental-specific notice that many dental practices (as well as dental schools and laboratories) will need to post at the entrance of the dental office by Aug. 30, 2018, unless the practice chooses instead to provide a warning with an informed consent form to be signed by the patient prior to exposure.