Radiologic Health Department Certification Presented by Natalie Beechler Health Physicist Brea X-Ray Inspection, Compliance, and Enforcement Unit
Where do our paths cross? In order to ensure properly educated and trained individuals are supervising and/or operating radiation emitting equipment, RHB inspections include a review of applicable licenses and certifications.
A brief history on governing Laws and Regulations... 1960: X-Ray Registration Act. Required all healthcare providers using x-ray to register their devices with the CA Health Department and report what shielding devices were used to protect doctors/patients. Assembly Bill 879 outlawed coin-operated foot x-ray machines in shoe stores.
Laws and Regulations... 1965 Senate Bills 848 and 849 849: Amended the Medical Practice Act to require physicians and podiatrists to take courses in radiology and radiation safety, and to pass an examination given by CA Health Department. Signed into law by Governor Edmund G. Pat Brown.
Laws and Regulations... 1968 Senate Bill 1056 A rewritten version of SB 848 that would require x-ray technicians and other licentiates (chiropractors) to have the same training courses and examination. Renamed previously created Radiation Safety Board as the Radiologic Technology Certification Committee: Four physicians One radiologic physicist Two x-ray technicians One chiropractor Signed into law as Radiation Control Act.
Present day: Who is licensed to use X-ray? Radiologists Physicians Radiologic Technologists Limited X-ray Technicians Chiropractors But, not all licenses are equal, nor do they imply the same privileges.
Let s Break it down. Radiologist Supervisor/Operators Prefix: RHLXXXXXXXX RHL Radiography Fluoroscopy
Radiologist certificate allows licentiate to supervise or operate radiographic AND fluoroscopic equipment.(rhl)
Health and Safety Code, Section 107110 States that it shall be unlawful for any licentiate of the healing arts to administer or use diagnostic, mammographic, or therapeutic x-ray on human beings in this state after January 1, 1972, unless that person is certified pursuant to subdivision (e) of Section 114870, Section 114872, or Section 114885, and is acting within the scope of that certificate
Let s Break it down. Physicians (Licentiates of the healing arts): Supervisor/Operators Prefix: RHC vs RHD Physicians Supervisor / Operator RHC OR RHD AND RHC Radiography ONLY RHC Fluoroscopy ONLY RHD Radiography & Fluoroscopy
Certificate for medical licentiate to administer or supervise BOTH radiography and fluoroscopy (RHD).
Deeper into the rabbit hole.. Radiologic Technologists Operator under a licentiate of the healing arts whom possesses a valid Supervisor/Operator permit RHT Radiologic Technologist RHF Prefix: RHT & RHF Radiography ONLY Fluoroscopy And/or Radiography
Radiologic Technologist, allowed to administer diagnostic x-ray UNDER THE SUPERVISION of a licentiate of the healing arts
Limited Permit X-ray Technicians Limited Permit Techs Operator under a licentiate of the healing arts whom possesses a valid Supervisor/Op permit Prefix: RHP Permit will be anatomy specific Digital vs film
But wait.mammography Mammography Technologists Operator under a licentiate of the healing arts whom possesses a valid Supervisor/Operator permit Prefix: RHM Mammography and/or Radiologic Technologist RHM Radiography and/or Fluoroscopy and/or
Mammography Interpreting physician CCR, title 17 30315.50 states an interpreting physician shall possess a current and valid radiology supervisor and operator certificate AND Meet the requirements specified in title 21, Code of Federal Regulations, section 900.12(a)(1).
Mammography (continued) 21 CFR 900.12(a)(1) Quality Standards, requires all interpreting physicians to meet initial qualifications, be licensed to practice in the State, be Board certified, have at least 3 months of documented formal training in interpretation of mammograms, have a minimum of 60 hours documented medical education in mammography, interpreted at least 240 mammograms within the 6 month period immediately prior to qualification, and must maintain continuing education by interpreting at least 960 mammograms in a 24 month period and have at least 15 category 1 CME s in mammography in a 36 month period.
Real time resource for verification Types of permit/ certificate expiration RHB Lookup http://rhbxray.cdph.ca.gov/default.aspx
Students! Students are exempt from required X-ray permits provided they are in an approved school for radiologic technologists (or limited permit x-ray technicians) when the students are operating x- ray machines and under the supervision of an instructor who is a certified radiologic technologist or a certified supervisor or operator.
Mobile X-Ray CCR, title 17, section 30309(b)(3) Personnel monitoring shall be required for all individuals operating mobile x-ray equipment. 30307(b)(1) Protective aprons of at least 0.25 mm lead equivalent shall be worn in the fluoroscopy room. 30447(a)(2) Limited permits issued pursuant to section 30444 exclude authorization to operate portable or mobile x-ray equipment.
First Time Violation
This is the voluntary Cease and Desist order for violations. This may include licentiates and non-licentiates.
Certification Violation You will need to write a letter explaining what happened and how you will prevent it from happening again. You will be required to take an on-line ethics course (which you will be required to pay for). You will have your certificate placed on hold until the matter is resolved. This may cause delinquent penalties to be imposed. You will have your CE s reviewed. You may be subject to other fines and penalties. Your employer may fire you.
High Risk Violations More serious violations or multiple repeat violations can lead to revocation, denial of renewal, and/or penalties. Penalties are based on when the activity started and how many x-rays were taken outside of the Regulations. Complaints may be forwarded to DOJ with penalties of over $100,000.
RHB Ultimately our goal is to maintain safety of the public, radiation workers, and the environment. We accomplish this through enforcing applicable state and federal radiation laws and regulations put in place to ensure safe usage of radiation. For more information, please visit us at: http://www.cdph.ca.gov/programs/pages/radiologicheal thbranch.aspx Natalie Beechler Phone: (714) 524-7705 Email: natalie.beechler@cdph.ca.gov