The “Proposed Virginia Radiation Protection Regulations” contains many new requirements however very few stakeholders were made aware of the comment period. Also the Appendixes are referenced as part of the regulation but are not available for review. I suggest a more through notification process for the stakeholders, and that the comment period should be extended three months after the appendixes are published. Comments on 12 VAC 5-481-10. Definitions. p. 42 "mAa" means milliampere. >>Should this read "mA" means milliampere? p. 43 "Misadministration" means the administration of: …. >>Consider using NRC’s term Medical Event instead of Misadministration. p. 48 Noise" means the standard deviation of the fluctuations in CTN expressed as a percentage of the attenuation coefficient of water. Its estimate (Sn) is calculated using the following expression: >>Consider broadening definition to include other imaging modalities p. 58 "Radiation detector">> Consider combining the two different “radiation detector” definitions that are on the same page but with different definitions. >>It seems that there are two similar but different definitions for therapy simulators. p 59 "Radiation therapy simulation system" p. 68 "Simulator (radiation therapy simulation system)" P. 85 "Written directive >> Will it be acceptable to order procedures through electronic charting instead of in writing? p. 77 "Teletherapy physicist" means an individual identified as the qualified teletherapy physicist on an agency license. >>Some faculties have more than one qualified teletherapy physicist; therefore, consider replacing the word “the” with “a”. p. 84 "Whole body" means, for purposes of external exposure, head, trunk including male gonads, arms above the elbow, or legs above the knee. >> Will Effective Dose Equivalent (EDE) correction factors be allowed for calculating occupational workers whole body doses that wear protective aprons? For example ((EDE = 1.5 x H1 + 0.04 x H2) where H1 is the deep dose component from the under-apron badge and H2 is the component from the collar badge. P. 97 12 VAC 5-481-150. Communications. All communications and reports …at the following address: Virginia Department of Health , Radiological Health Program, 1500 E. Main Street, Room 240, Richmond, Va. 23119-2448. >>Is the address correct? P 106 12 VAC 5-481-280. Shielding plan review. F 1 a. >>Will there be a grandfather clause for existing control booths that are less than 7.5 square feet and/or with a dimension that is less than 2 feet? If allowed will the grandfathered dimension be allowed with installation of a new console? P 115 12 VAC 5-481-340. Private Inspector Qualifications. 12 VAC 5-481-340 A 2 a >>The total required credit is 15 CME per 3 years and since MQSA requires 15 CME per 3 years and since many CME programs are designed to provide the needed credits in one trip to a 15 hour course, consider changing the State requirement to match MQSA’s time cycle of the same total but over three years instead of the current 5 per year. 12 VAC 5-481-340 C 2 a. Continuing education…..This continuing education shall include training appropriate to each mammographic modality evaluated by the private inspector …>> MQSA no longer requires that the training be specific to the modalities evaluated. P 122 12 VAC 5-481-370. Certification of X-ray systems. A 4. Certification may be denied if any non-compliances are not corrected within 45 days from the date of inspection. >>Will both serious and non-serious non-compliances have the same time limit for correction? P. 207 12 VAC 5-481-740 B 6. Sealed sources, except teletherapy and brachytherapy sources, which are stored, not being used and identified as in storage. >>Stored not in use Brachytherapy sources should also be exempt from leak testing to help keep workers hand doses ALARA. PART VI USE OF DIAGNOSTIC X-RAYS IN THE HEALING ARTS 12 VAC 5-481-1580 Throughout the Diagnostic sections consider using the word image in place of film, as many facilities are now “filmless” This will avoid a potential loophole for imaging that doesn’t use film p. 295 12 VAC 5-481-1590. General and administrative requirements. A. 1. An X-ray system which does not meet the provisions of these regulations shall not be operated for diagnostic purposes. >> Does this mean that the any system will have to be immediately removed from service for any minor separation form the requirements? 12 VAC 5-481-1590 B 2 b The darkroom shall be light tight ……fogging of the film. >>How often will darkroom fog have to be determined for non-mammography darkrooms?