OSRT Advocacy Update

Ohio Department of Health - Radiation Advisory Committee (RAC)

The Radiation Advisory Committee met at the Ohio Department of Health on October 21, 2022. A quorum was not present, so the meeting was for information only. The OSRT had representation attending this meeting to serve as the voice of Ohio Technologists.

 X-Ray Program

  • Conducted 30 on-site hospital inspections, 79 MQSA inspections, 22 free standing imaging sites.
  • The department still has 3 open positions in the health physicist category.

    Radiologic Technologists are uniquely qualified for these positions. If you have an interest in working on the legislative side of radiation safety, please contact the Department of Health.

  • No medical events (impacting radiation to patients) were reported during this quarter.
  • The draft rule 3701:1-38-04 (Radiation Generating Equipment Inspection Schedule and Inspection Fee) is out for public comment until January 21, 2023. Submit comments to the proposed rule. Anyone can provide comments on any rule, or if you prefer you can contact the OSRT and voice your opinion.

Bureau of Environmental Health and Radiation Protection (BEHRP)

  • The department has been called for clean-up regarding I131contamination in a land fill and a radium contamination in a public area from a closed industrial steel facility.
  • The Bureau continues to work on clean-up of the Co60 contamination in a residential area in Cleveland from the old (defunct) Picker Medical site.

The next RAC meeting is tentatively scheduled for January 20, 2023. These are open to the public.

Navigating Ohio Department of Health Rules

Ohio Administrative Code (OAC) rules that begin with 3701:1 are rules pertaining to radiation control and are the responsibility of the Bureau of Environmental Health and Radiation Protection (BEHRP), Ohio Department of Health. The numbers that follow 3701:1 indicate specific areas of radiation use and usually include multiple chapters (designated by additional numbers).

Number Title/ Radiation Category

3701:1-37 Physical Protection Program
3701:1-38 License or Registration for Radiation Handlers
3701:1-40 Byproduct and Accelerator Produced Material
3701:1-43 Technologically Enhanced Naturally Occurring Radioactive Materials
3701:1-44 Issuance of Licenses
3701:1-46 Byproduct, Accelerator Produced Material and Radium Licensing
3701:1-48 Licensing and Safety Requirements of Industrial Radiography
3701:1-49 Licensing and Safety Requirements for Well Logging
3701:1-50 Packaging and Transportation of Radioactive Material
3701:1-52 Licensing and Safety Requirements for Irradiators
3701:1-54 Radiation Generator and Broker Reporting Requirements
3701:1-56 License for Special Nuclear Material
3701:1-58 Medical Use of Radioactive Materials
3701:1-66 Radiation Generating Equipment
3701:1-67 External Beam Radiation Therapy Equipment
3701:1-68 Industrial Radiation Equipment
(bold type indicates rules predominantly for medical radiation uses)

The only rule that pertains to Licensure for Radiologic Technologists and GXMOs is 3701-72.

In unofficial conversation, these rules are generally referred to by the last 2 numbers, i.e. “the 72 rules”.

Radiation Generating Equipment Committee (REC)

The REC met on October 14, 2022. The OSRT had several individuals in attendance to provide input and speak for the profession.

  • Performed 5-year review of OAC 3701-72 Radiologic Licensure of Individuals. This is our Licensure Rule!!!
    • Changes to the wording are being proposed that would impact the operation of hybrid units (PET/CT and SPECT/CT) by licensed Nuclear Medicine Technologists. The OSRT is working with experts in our field to assure the wording adequately reflects our clinical practice.
    • The Department is suggesting the insertion of the term “Localization” to the definition of CT Procedures. The OSRT feels this term is too ambiguous and means different procedures to different radiology practioners. We will continue to pursue this for clarity.
  • Reviewed and discussed all public comments submitted regarding changes to OAC 3701:1-68 (Non-Medical Radiation Generating Equipment).
  • Performed 5-year review of OAC 3701:1-38 chapter 04 (Radiation Generating Equipment Inspection Schedule and Inspection Fee) . No changes were proposed.
  • Performed 5-year review of OAC 3701:1-66 ( Medical Radiation Generating Equipment) Chapters 1-XXX. A few changes were suggested by the committee. These will be reviewed by ODH legal department and sent out for public comment.
    These are the rules which directly govern the equipment that we use in radiography, so close attention is imperative!

No future meeting dates were set.

Potential Challenge to Radiology Practice

The OSRT is closely watching a possible effort to change the Radiologic License rules or statute to weaken the supervision required for GXMOs to practice.
Currently GXMOs are required to have direct supervision by a licensed practitioner which requires that the supervisor be present at the location and in immediate proximity.
Radiographers, Nuclear Medicine Technologists and Radiation Therapist practice under general supervision, the supervisor does NOT need to be present at the location where the procedure is being performed but must be accessible.

This effort seems to be to loosen the level of supervision for GXMOs so the supervisor would NOT be required to be at the site, effectively giving them the same level of supervision as Radiologic Technologists.

The OSRT is concerned about the impact on patient care, as GXMOs have very limited education relative to radiation protection, with some didactic courses being offered solely on-line. There is little monitoring of the educational/ clinical experience for accountability.

The OSRT will continue to monitor this and work to assure quality radiation care for our patients. Help us. Join us so we can continue to fight on behalf of you and Ohio consumer patients!

 

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