12 VAC 5-481-3430 R 1 a: This paragraph seems to require that the same radiation therapy physicist perform both calibration and protection surveys. These are two different subspecialties of medical physics and not all radiation therapy physicists do both. The wording should be modified to explicitly accommodate the fact that protection surveys may be performed by a different qualified expert than the calibration and other tasks of 12 VAC 5-481-3430 R 1. 12 VAC 5-481-3430 T 2, 12 VAC 5-481-3430 T 3, 12 VAC 5-481-3430 U 1, 12 VAC 5-481-3430 U2 and 12 VAC 5-481-3430 U 6: The AAPM task group reports cited were meant to be advisory documents to be used by qualified medical physicists in the development of acceptance and quality management programs that are appropriate to the local circumstances. Furthermore, much of their content has been rendered somewhat obsolete by recent rapid developments in technology, and the AAPM is in the process of dramatically revising their recommendations. It is inappropriate for these specific task group reports or their specific recommendations to be included in their entirety as regulatory requirements. 12 VAC 5-481-3430 U 7 f: Weekly checking of all emergency power cutoff switches is excessive and burdensome. Many therapeutic x-ray machines have They are typically tested monthly at most (as is recommended by the AAPM’s TG-40 report). The language of this paragraph is unclear as to whether one switch per week must be tested or whether all switches must be tested weekly or whether the facility retains discretion to determine the appropriate testing schedule. 12 VAC 5-481-3450 B: There is no Appendix O. Missing: The proposed regulations do not specify the protocol by which a teletherapy unit is to be calibrated. It would be preferable to require that a teletherapy machine be calibrated using a protocol currently recommended by the AAPM.