The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
#120 Be Prepared for Your Practice's Radiation Safety Inspection
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All dental practices are subject to safety inspections of their radiography equipment. Each state determines the frequency of the inspections, and the safety requirements. Learn how to access your state's requirements, and be prepared when the inspector walks in the office and feel confident that your equipment will pass inspection.
- EPA Radiation Protection Programs Map: https://www.crcpd.org/mpage/Map
- OSHA Ionizing Radiation: https://bit.ly/44pvTGs
- American College of Radiology Technical Standard for Diagnostic Medical Physics Performance Monitoring of Radiographic Equipment: https://bit.ly/3R0n9n8
Welcome. I'm Leslie Cannon. I'm Mary Gavoni.
SPEAKER_02I'm Linda Harvey. I'm Olivia Wan, and together we are the Compliance Divas.
SPEAKER_03Welcome to the Compliance Divas Podcast. I'm Mary Gavoni and I'll be the moderator for this episode. We bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. You can subscribe to the Compliance Divas podcast through your favorite podcast channel or on our website, thecompliancedivas.com. The resources we mentioned during our podcast can be found on the compliancedeevas.com website, and you may always submit questions to by email to support at the compliancedevas.com. Diva spelled backwards is avid. And that describes all of this group of experts in OSHA HIPAA regulatory compliance that we are avid advocates for safety and documentation and all the things that help a practice to be successful in making sure they meet regulatory requirements. So every dental practice or every dental facility has x-ray equipment that must be by law inspected by state officials. And it's inspected at different intervals depending on the state. And it's important for every practice to know what the requirements are for their state and to be prepared for an inspection, which in many cases is unannounced. So, Leslie, will you start us off, please, and discuss how one might know what the intervals are for radiation or radiography inspections and how important it is for people to check with their states?
SPEAKER_00Well, Mary, you know, there's two levels that are described in the resources that we will provide to our listeners. And one is performance evaluation and the other is quality control program. So after a new machine is installed, the uh after acceptance of testing, the performance of each radiographic system should be evaluated at least annually, or upon replacement or repair of a major component, or upon a change of designated use that may affect the image quality, or if there's a patient or staff radiation dose that is changed. And equipment performance and usage may necessitate increased periodic testing. There is in the resources we will provide what's called an appendix A, which is a table that uh has the local uh recommended parameters that would be evaluated during an annual performance evaluation for radiographic equipment. So I encourage our listeners to download that resource and take a look at Appendix A. Now, quality control is a continuous quality control program that must be implemented for all radiographic equipment. And the dentist would be responsible for that. The quality control program should be established by the dental practice, and it can be with the assistance of a qualified medical physicist, which is like a health physicist, or those are the folks that come out and actually inspect uh x-ray equipment in the various states. And it should include but not be limited to the quality control tests that are listed in Appendix A. There should also be somebody at a dental office who's responsible for either performing the test or uh getting together with a qualified medical physicist and then modify the frequency of testing based on the system's complexity, usage, and performance. Now I know here in California we have a very robust radiation safety program, and the radiation safety audits happen frequently. I got calls from clients all the time asking me what they should do and how much uh the time they should reserve and what kind of citations have been issued. And I've always offer the information about contacting the uh State Department of Health Services radiologic branch. And again, fortunately for our listeners, we have a great map that is included in our resources that gives uh information on where you can contact your own radiation safety board for your particular state and get the information about frequency of inspections and uh how to prepare for an audit. Usually they provide some steps that you can follow in a guideline of what to expect when you're going to be inspected.
SPEAKER_03Great information, Leslie. And one thing that many offices may not be aware of that there are many states that require someone on site to be the radiation safety officer, or they call it the RSO. So again, use that map to click to your state's Office of Radiological Health or whatever it's called in your state, and make sure that you know what those requirements are. Linda, can you talk to us about documentation that's needed for a radiological inspection?
SPEAKER_01Mary, it's been my experience that each state certainly has quite different requirements when it comes to documentation. As Leslie just mentioned, they have some pretty stringent requirements in California and have to have their radiation plan and policies. Other states that are similar would be South Carolina and North Carolina, just to name a couple. So each state has their own entirely different documentation and requirements for posters, even radiation monitoring. One of the areas that I'm seeing the most distinction now is with the handheld radiation devices. And that's been an evolving area of new laws in the past five plus years, just because of the growth of the popularity and the different models that are available now for handheld radiation devices. So I want to caution our listeners, Mary, that not all handheld radiation devices are approved in every state. And on top of that, there are different radiation monitoring requirements that vary state to state. For example, here in Florida, that's the one item that is required to have a monitor in Florida is the radiation, handheld radiation devices when they're used in a practice. So that's one example of some differences there. In addition, I know in Tennessee, they're required to have a finger radiation badge when they're using handheld radiation devices. And that's been in effect, I think, even longer than our Florida law. So I want to caution our listeners to really take advantage of the resource that we're going to have today to be able to look at their state laws and determine what are the guidelines that are specific so they can be in the know from the very beginning. I know we just did some research in New Jersey, for example. And one of the different models for the Nomad handheld device, the GBL, cannot be used in their state. I'm not sure it can be used anywhere else because it's meant for global export, which will have different radiation requirements for different countries. So it's very important because sometimes, Mayor, we know offices are trying to save money in their budget and will buy things from eBay or from someone else that's not a bona fide agent or company for selling these devices and might end up in a pinch and have the wrong device and then get caught during their radiation inspection. So something to really key in on. And I just want to encourage our listeners to take a look at that link for the resources for their practice.
SPEAKER_03That is so important, Linda. Um, and you are so right. People are really going to non-traditional sources to buy some of their equipment, and there could be obviously some repercussions for that. Um, one of the things that we has evolved, of course, with digital radiography is the need for calibration to make sure that the images are optimal or of optimal diagnostic quality. And Olivia, can you tell us a little bit about how what does an office do for calibration of their units, and especially if they have a C B C T machine?
SPEAKER_02Well, Mary, I think it's important that we always resort to following the manufacturer's instructions for calibration. And that's especially true for C B C T. Now, with these cone bean scans, you know, it is a higher radiation dose than a typical digital radiograph, but it's important to recognize that it's still much lower than conventional computed tomography scan. But once again, we have to follow those manufacturers' instructions. The American Dental Association's Council on Scientific Affairs has produced some position statements about CBCT in daily clinical practice because it has become so common. And I cross-reference that to an issue in JATA, the journal of the American Dental Association. And one of the points made in that article, Mary, is that staffs of facilities using CBCT should establish a quality control program. This program can be based on the manufacturer's recommendations or can be established, implemented, or monitored by a qualified expert. So in working with my clients, especially here in Tennessee, I always work closely with an expert and recommend an expert, namely Kevin Christian. And a lot of my clients use his services because he is so up to date on state-specific rules and making sure the equipment is checked. And when they use a professional like Mr. Christian, then they send that information in rather than waiting for a state inspection. So there's some incentives of hiring your own inspector. But once again, Mary, I think the key is just to make sure we're following manufacturers' instructions and that we're working with qualified technicians because it's all about safety, safety for the staff as well as the patients.
SPEAKER_03Absolutely, Olivia. And thank you for that suggestion about being proactive. Bring someone in to compile the reports and even submit them. So once when those um systems are installed, the installers, the from the manufacturer or that are trained through the dental distributor are the ones that you can call on to come and do those calibrations. In many cases, somebody can come from the manufacturer to do that. And it's just, I think, a matter of establishing that that should be an annual protocol, or sooner, if you're starting to see issues with some of the scans or the images that you're taking. And that is one of the things that the inspectors will look for is that, and I think Leslie or Linda, you're the ones that meant mentioned quality control, and it has to be a continuous process. Um, so the the bottom line here is make sure that you know what your state's requirements are. Do you need a radiation safety officer appointed? Do you need a radiation safety formal policy and or a manual with information about your equipment and about protocols? And how often will you be inspected? And um, what happens as a result of that? And if you did not pass an inspection, is the state going to prevent you from using your equipment? Are they going to fine you? What kind of things do you have to do to make sure that you have corrected any issues?
SPEAKER_00Leslie. Well, in California, it's again a pretty big issue getting these inspections conducted, and dentists are nervous about them. I can tell you some of the findings of the outcome of inspections that might help our listeners. One is, of course, the written radiation safety plan and that being reviewed, at least looked at and signed off annually. Secondly, is uh some kind of record of dosemeter testing, especially since we have many women of childbearing age coming in working in dental practices. And then uh, I guess this also kind of borders on OSHA as well, is uh some kind of a written plan for pregnant employees where they have either uh instructions on uh either not to expose images or radiographs, or they've got permission from their OB to go ahead and do it, but they have to wear decimeter badges both for themselves and over the fetal area. And then just one other thing I think that we need to add that we've lost track of is many states require a payment for their x-ray permit that's issued in California, it's a biennial type of basis. So every two years they have to pay their renewal fees. And sometimes the Department of Health Services doesn't send out billings. So I think each and every dental facility is responsible for making sure that they pay and stay up to date on their x-ray equipment so they don't get in trouble otherwise. COVID made us uh lose focus on a lot of things and renewing certain permits, such as your radiation equipment permit, is something we cannot lose track of. It needs to be on our calendar. Thank you for that great reminder, Linda.
SPEAKER_01Mary, I'd like to pass along another tip that we experienced here in Florida, just something that, you know, sometimes you you, as much as we all read our laws and rules in different states and uh across the country, sometimes you miss something. So I will say that we had missed a little detail that got picked up by Radiation Inspector, whereby with cone beans and panorakes machines, you have to be able to see the patient while the film is being exposed. So I want to pass that tip along because sometimes we miss little details. Admittedly, that happens to all of us. So the client simply just put in a mirror and then they chose to hang the x-ray apron over that so that way it didn't look like it was obtrusive with their decor. But regardless of whether that's a requirement in your state or not, I think that every practice needs to evaluate that piece because you never know when there could be something uh could happen to the patient. It could become faint or some issue, and you just want to be able to visualize the patient during the exposure, and you don't want them to move and not get the exposure that you intended. So great little tip to pass along, Mary.
SPEAKER_03Oh, absolutely. And I do know that that's also a requirement in Texas. So I imagine that it is in other states. So I realize that we've just given our listeners a lovely homework assignment to go and and check on their state requirements, but it's good to know it's a good review. Make sure you understand what's going on. One of the questions that I get a lot is does OSHA require um dosimeters? And on a federal level, OSHA does not, but some states do, and some states require them, as um, I think um you said, Linda, um, just for the handheld devices, a ring dosimeter and so forth. So can't emphasize enough how important it is. Go to your state office of radiological health, or again, whatever it's called in your state. Make sure you review those requirements. Be prepared so that you can pass a radiation inspection with flying colors. So thank you for joining us for this episode. We bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. You can submit any questions by email to support at the compliancedevas.com. All the resources that we mentioned in today's podcast will be available in the show notes on your podcast app and also on our website, thecomplicedivas.com. Please join us again for the Compliance Divas podcast.