Regulatory Compliance
C D A J O U R N A L , V O L 4 9 , Nº 5
Radiation Safety Checklist CDA Practice Support
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wning and operating radiographic equipment requires compliance with safety rules enforced by the California Department of Public Health (CDPH) and, for those with practices located there, the radiation programs of Los Angeles and San Diego counties. This article summarizes the regulatory requirements for radiation safety.
Machine Registration
Owners of X-ray units must register them with the CDPH. The report or form completed by a vendor or distributor of X-ray equipment is not a registration form. Only the equipment owner may register it. Registration is site specific, so a change of address must be reported if a dental practice moves. Owners may use an online form on the CDPH website to register equipment and to report an address change, removal of equipment, change of ownership and practice closure. Owners are billed registration fees every two years. Dental practices in Los Angeles and San Diego counties also are required to submit shielding plan review documentation to their respective radiation program. A portable dental X-ray system cleared by the FDA and used in a manner consistent with that approval may be used in California. The unit should have a backscatter shield that is at least 0.25 mm lead equivalent and permanently affixed. The dental practice that owns and uses such units must have in possession a valid exemption letter from the CDPH (found on the CDPH website).
Regulations also require the machine operator to be behind a protective barrier (lead apron) during each exposure.
Operator Licenses or Certificates
An individual who operates radiographic equipment must have a license from the Dental Board of California and a certificate of completion from a board-approved radiation safety course or a board certificate indicating education equivalent to the boardapproved course.
Posted Notices
“Caution X-rays” signs must be posted where radiographs are taken. “Notice to Employees” (RH-2364) is included in the CDA-provided poster set. If the practice has received a notice or order related to radiological work, it must be posted along with any required response.
Dosimeters/Occupational Exposure Records
Records of occupational exposure to radiation must be kept and be made available to the CDPH upon request. Methods for developing these records include employee use of dosimeters and utilization of a health physicist. An exception to monitoring is allowed when it can be demonstrated that no employee is exposed to more than 10% of the maximum allowable annual dose, which is 5 rems. If the exception is met, monitoring should occur periodically to ensure that exposure does not exceed this amount and as long as no significant exposure is demonstrated or no radiographic equipment is changed.
An individual who uses a portable unit must wear a dosimeter, except for users of devices identified in the CDPH’s exemption letter. A declared pregnant employee who operates X-ray equipment should wear a dosimeter once the employer is notified of the pregnancy.
Written Safety Plan
Dental practices are required to have a written radiation safety program. The document should describe procedures and devices (engineering controls) that dental professionals use to ensure that occupational doses and doses to members of the public are as low as is reasonably achievable (ALARA principle). A CDA-provided template allows a dental practice to adopt the Radiation Safety Guide into its written program. The guide includes a copy of the state (Title 17) and federal (10 CFR 20) regulations applicable to dental practices. It summarizes standard practices and requirements in the following areas: ■ Responsibilities of the licensed dentist and radiographic machine registrant. ■ Requirements for dental radiographic machines. ■ Patient protection. ■ Responsibilities of dental personnel operating radiographic equipment. ■ Quality assurance and quality control. ■ Equipment quality assurance requirements. ■ Guidelines for prescribing radiographs. ■ Occupationally exposed women of childbearing age. ■ Protective barriers. M AY 2 0 2 1
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