Action | Repeal existing regulations and adopt new regulations with up-to-date radiological health standands |
Stage | Proposed |
Comment Period | Ended on 9/29/2005 |
8 comments
on page 307 of this document it notes that only state licensed technologists and ARRT certified technologists may operate x-ray equipment. This needs to be ammended by adding "or students enrolled in a school of radiologic technology that is accredited by an orginization acceptable to the ARRT such as the JRCERT". In addition there should be a gratis time from the date of graduation until the technologist becomes ARRT certified. Such technologists are registry elligible but may not have recieved their test date and thus may not be ARRT certified for a period of time to be agreed upon.
The present proposed regulation would limit both mammographic and diagnostic physicist working at one facility from surveying their own facility’s equipment. This is not the case in therapy. Therapy private inspectors are required to complete only one facility and one unit per year. This makes no sense. The mammographic requirements are three times that of the present Federal MQSA standard which only require 2 facilities in a 24 month period. Why the State would choose to supercede the federal requirements, is not clear. The requirements for diagnostic inspections seem unusually high, 10 facilities and 20 tubes. Why they need to exceed the requirements for mammography is unclear.
I would propose that the mammography requirements be aligned with those of the MQSA and that the diagnostic be similar to therapy in that they require 1 facility and 3 tubes in a 12 month period.
If passed in their present format, the regulations would severely impact on the ability of facilities to get required surveys done by placing unnecessary restriction on the physicist performing diagnostic surveys and undoubtably increase the cost to those facilities.
Nothing in these regulations defines either the educational, continuing education or continuing experience requirements for State Inspectors. I think it is in the public healths interest to ensure that State Inspectors meet the same minimum requirements for the inspection of facilities and equipment that are required for Private Inspectors. It has been implied in the past that they do so by job definition but that is not clearly delineated in these regulations and thus allows the State to employee State Inspectors who are not qualified to meet the same level set forth in these regulations. This is not only misleading to the registrant who might choose to use them but an unfair competitive edge since the State is in essence competing with the private sector in this market. At a minimum, State Inspectors should have to meet all of the educational, continuing educational and experience requirements set forth for Private Inspectors if they are going to provide inspection services for a fee.