With an eventful 2020 coming to a close, we wanted to update you on a few items for the next year. As we work ahead of upcoming regulatory changes, you'll have the most current information in your Digital Radiation Safety manual going into 2021 - but some intervention is still required in order to ensure your program is compliant.
The items we've listed below will be critical in your 2021 Annual Meetings and Inspections.
- ALL of the topics outlined within the Safe Operating Procedures (Section 5) and the Instructions to Individuals (Section 6)within your digital radiation safety manual are important and must be discussed with all employees during your Annual Meeting, the items below are highlighted for 2021 because the Ohio Department of Health inspectors will now be enforcing the following requirements from the Ohio Administrative Code.
- Facilities will be held responsible for compliance pertaining to Ohio Administrative Code 3701:1-66-06(D)regarding annual x-ray operator evaluations beginning December 20, 2020. The annual evaluation of x-ray operators must include the following: positioning of the x-ray tube, image processing, operator location during x-ray exposure, appropriate radiologic protocol, and applicable regulatory requirements. Your facility is encouraged to begin annual evaluations of x-ray operators as soon as possible as the facility will be held accountable for this requirement at the next inspection. This requirement is specified in section 6 "Instruction to Individuals" and bullet-pointed on each Equipment Training Sheet in section 6. Once each licensed operator is trained on each of the above-listed items and signs the Equipment Training Sheets, they will meet the annual x-ray operator evaluation requirement.
- Facilities will be held responsible for compliance pertaining to Ohio Administrative Code 3701:1-66-02(J)(11)regarding Annual Protective Apparel Evaluations beginning December 20, 2020. Your facility is encouraged to begin annual protective apparel (Lead aprons) evaluations as soon as possible as the facility will be held accountable for this requirement at the next inspection. A Protective Shielding Evaluation form is provided in section 10 of the Dental Radiation Safety manual. A clinical employee must be designated on the form to perform the yearly evaluations.
- X-ray Order Policy (OAC 3701:1-66-04(B)(17): Only licensed practitioners can order diagnostic radiographic examinations. This requirement is outlined in section 5 "Safe Operating Procedures". The preventative protocol described in section 5 "Safe Operating Procedures" is essentially a pre-approved set of radiographs that are taken during preventative appointments. Diagnostic radiographs must be "signed-off" or approved by the licensed practitioner(s) on staff and must be designated by the practitioner's initials or signature in the patient's progress notes. The method used to achieve this requirement may depend on the software used by your practice. It is important that whatever method is chosen to record the licensed practitioner's approval of radiographs is used consistently among all clinicians in the practice.
- Employee Pregnancy (OAC 3701:1-66-04(B)(11)): An Employee Pregnancy Notice explanation is located in section 6 "Instruction to Individuals" and a form for the pregnant employee to fill-out is also located in section 6. Once the form is completed and signed by the employee the form must be stored in the employee's file and must remain confidential.
- Due to unforeseen COVID-19 related issues, Novallier was forced to make some internal changes, delaying the progress of a number of features including the much-requested e-signatures. Work on e-signatures and other features continue though, and we expect to have an update for you soon!
- Some members who joined earlier this year may still be using a deprecated version of the Equipment Training document, and are missing the Employee Pregnancy Notice document. If you require an updated copy, please reach out to us so that we can get you up to date.
As always, please feel free to contact us with any questions and concerns.