Radiation Inspection Requirements T


MDA works with MRCP to provide resources, including dedicated web page, to aid in compliance


hree years ago, in the March/April 2017 issue, the MDA announced it had created a web page to help mem- bers compliance with the state requirement to have radiation machines inspected. Even then, this was not a new requirement. In our March/April 2013 issue, MDA reported that beginning January 2013, all offices through- out the state that utilize radiation equip- ment began receiving correspondence from the Missouri Radiation Control Program (MRCP), referencing 19 CSR 20-10.050, which stated that facilities must have radia- tion surveys performed by Qualified Experts (the state would no longer be performing these at no cost and at random intervals) and that this requirement would be actively enforced for all facilities beginning a year later, January 2014.


Since that first announcement, we’ve featured this regulatory compliance topic in several Focus issues as well as in eNews updates, including promoting the web page (modental.org/radiationinspections) that includes various resources—among those a list of all members’ inspection due dates (up- dated February 2020) and a list of Qualified Experts (QE) who can perform the inspection and provide the necessary report to the state.


We recently followed up with John Langston, Administrator of the Bureau of Diagnos- tic Services (including the MRCP) in the Missouri Department of Health & Senior Services, to inquire about changes or news to share with members.


Langston reviewed all information provided on the MDA web page and affirmed that all the information about processes remained unchanged. However, he did note that as of the end of February, the Program was just over 50 percent through the Class D facili- ties (which most dentists are) getting their first mandatory inspection by a QE. He said almost 700 dentists/offices still are due be- tween now and December 31, 2022 and those practices don’t yet have a QE established.


which equates to inspection by a QE every three years for CBCT units. (Other radia- tion machines—intra/oral, traditional 2D panoramic—still get inspected only every six years.) Langston said he is aware of a few examples of equipment salespeople who have downplayed both the potential for higher ra- diation exposure to patients and staff, as well as more stringent regulatory requirements, in order to make the sale.


GUIDANCE & RESOURCES MODENTAL.ORG/RadiationInspections


“It seems every month we still get calls from people surprised by this requirement to have an inspection performed by a QE, even though since 2012 we’ve stated in every letter we send to them that this is coming,” Langs- ton said. He shared the following points to remember as dentists prepare to have machines inspection:


The facility should not rely on the dental equipment service company to ensure regula- tory requirements are met. It’s the dentist/ equipment owner’s responsibility, but the MRCP still hears “the vendor people said they were taking care of all of the paper- work.” Vendors do have some responsibility, but those are limited, and they may not be aware of all the requirements, especially if they are in another state that may have different rules. Regardless, if there are any changes with the x-ray machines, especially relocating or adding new units, the facility’s best option is to contact the MRCP on the front end to ensure they stay in compliance.


CBCT units continue to expand. As of right now, of the more than 2,000 registered den- tal facilities the MRCP has, approximately 24 percent have CBCT units. This means 76 percent do not (or are not registered), but MRCP anticipates the numbers of CBCT units will only increase. Dentists considering purchasing those units need to be aware up front of the additional costs of ownership (your practice becoming a Class E facility,


MRCP is being directed to shorten enforce- ment response windows for facilities not com- pliant with registration and/or QE inspection timeframes. In the past, MRCP sent second or third reminder letters to facilities that were past their compliance date. This led, in some cases, to facilities being out of compliance for months before MRCP finally got them to act. Langston says the Program has been directed to tighten that up. “In the next month or so, once a facility (any type of facility, not just dental) is determined to be out of compliance with established time frames, they’ll probably get an immediate warning letter, and if they don’t resolve the issue within a few days, we may issue an emergency order to cease using the x-ray equipment, or take legal action with the state Attorney General’s office or the clinician’s licensing board,” he said. He stated that most facilities are compliant, but the small number that ignore repeated letters or emails consume a lot of the Program’s band- width. “I want the MDA and its members to be aware of this shortened enforcement time frame.”


Langston concluded saying, “the goal of these inspections has never been to trip anyone up. We want them to comply and want to help them achieve that by answering any ques- tions they may have.” Both he and the MDA hope the resources available on modental. org/radiationinspections will help members significantly by explaining the process, pro- viding inspection dates and links to QEs, and answering a variety of FAQs. f


ISSUE 2 | MAR/APR 2020 | focus 19


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