General items for review
- 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. Be sure that the required signature documents have been completed for the year. Inspectors look for consistency and accuracy when completing the annual requirements. The items below are highlighted because the Ohio Department of Health inspectors are now 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 (Protective 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.
- The Ohio Department of Health requires radiation device calibrations be performed a minimum of once every 5-year inspection cycle. However, due to the high volume of use these devices undergo in a dental office setting, equipment manufacturers may recommend calibrations more frequent than the 5-year cycle to ensure optimal accuracy and performance. 3701:1-66-04(B)(1) requires the facility to set/indicate a calibration frequency. All calibrations must be performed by a qualified Calibration Service Handler.
Dental CT devices may have different requirements regarding calibration/evaluation frequency. Please reference the manufacturer specifications, physicist report(s), and service handler recommendations for device specific requirements.
For facilities with Dental CT units
- Prior to patient use and operation, handlers are required to utilize a radiation expert to determine compliance with exposure levels in accordance with 3701:1-38-14 of the Ohio Administrative Code by performing an area radiation shielding and survey (physicist report must be available to the Ohio Department of Health's inspector upon request [3701:1-66-02(H)(1)(d)])}.
- On an annual basis: an assessment of radiation dose and image quality, and upon new installation or re-installation, after any change in structural shielding (unless in the documented determination of a radiation expert, the re-installation or change will not cause a significant increase in radiation hazard), or an increase in the clinical workload which exceeds the assumptions used in the existing radiation survey. The individual responsible for radiation protection (Radiation Executive Officer) shall obtain from the radiatin expert a written report of the shielding design and the area radiation survey. A copy of the report shall be made available to the Ohio Department of Health's inspector upon request [3701:1-66-02(H)(1)(d)]. Section [3701:1-66-10(C)(1)(a)(ii)(c)] requires the radiation expert's approval of the designee's test results be documented within 30 days.
- Dental CT constancy tests are required and should be completed in accordance with the area radiation survey or the manufacturer's operational specifications. Constancy tests must be made accessible to the Ohio Department of Health's inspector upon request. Licensed operators with quality control responsibilities must be trained, by either the device manufacturer or by following the procedures specified in the device operator's manual, to perform proper constancy tests [3701:1-66-04(B)(14)]. The frequency of the Constancy Tests performed must be noted on the Dental CT Constancy Test Training form in section 6 of the Radiation Manual, refer to the Physicist Report for details.
If you have questions or concerns prior to your annual employee meeting or Ohio Department of Health inspection, please feel free to reach out to us - we're happy to help!
If you are a subscriber to a Novallier FoxPath support plan and your facility has made policy, procedure, and/or radiation equipment changes, please contact us so that we may assist you in updating your program.