alized advice and guidance on personnel radiation monitoring. If you wish to seek the consultation of a QE prior to your facil- ity’s inspection due date, MRCP keeps an active list of Qualified Experts available on the MRCP website at http://health.mo.gov/ safety/radprotection/pdf/QE-List.pdf. Exist- ing facilities were first notified by mail of their normal QE due date in 2012, but if you have questions you can contact the MRCP at MRCP@health.mo.gov.


For those existing facilities that wish to make an informed decision about monitoring before your QE performs an on-site inspec- tion, you have three basic options.


 Badge/Monitor all exposed staff. Cer- tainly the easiest and safest answer is to monitor all exposed staff. That covers all the possibilities, and provides the maximum amount of protection, both for your staff and yourself. However, that may not be required by regulation. It depends on a number of factors which may be difficult for the dentist to ac- curately determine.


 Don’t monitor any staff. Based on the NRCP estimates cited above, most op- erators in a dental setting do not require monitoring. Not monitoring is certainly (on the surface) the least expensive choice. But not monitoring based on NCRP estimates alone remains only an educated guess if you have not had an evaluation by a Qualified Expert. It also incurs a slight element of risk for both your operators and yourself. It’s very unlikely, but what if an employee claims they were overexposed, or an OSHA investigation on employee exposure is initiated? Without any data points, it may be difficult to demonstrate that monitoring is NOT required. Monitor- ing dental operators can be seen as a form of liability insurance, albeit one that may be unnecessarily expensive for the actual risk mitigation.


 Monitor all exposed staff for a lim- ited amount of time. An intermediate method that can provide your practice with radiation safety data without the cost of ongoing monitoring is to monitor staff for a set period of time, typically at least a year. This provides


at least a baseline measurement of radiation exposure to your staff and can assist you in determining the need for continuing monitoring. Make sure you retain records of this information as a demonstration of compliance. Also note that if your practice workload increases significantly, the evaluation might need to be repeated.


Radiation personnel monitoring (dosim- etry service) is available from a number of companies, with typical reporting periods being monthly or quarterly. Most monitoring companies track both exposure in the cur- rent reporting period as well as cumulative exposure. If monitoring is done, employee dosimetry records must be maintained for at least five (5) years, and the employees made aware of their exposure. A common method of notification is to have all monitored staff review and sign the periodic report. It should also be noted that due to concerns regard- ing identity theft, MRCP no longer enforces the requirement that radiation monitoring records include the employee’s social security number.


Missouri Radiation Control Program rule 19 CSR 20-10.060 Radiation Exposure Records and Reports


(3) Upon termination of employment of an individual…upon request, shall be supplied with a summary statement of that individual’s radiation dose. (The estimated maximum dose shall be stated if no personnel monitoring has been carried out.) …Employee [exposure] records must be kept…during the tenure of employment of an employee and for a period of five (5) years after that.


OSHA standard 1910.1096(b)(2)(iii)


“The employer maintains adequate past and current exposure records which show that the addition of such a dose will not cause the individual to exceed the amount authorized in this subparagraph.”


DOES DENTAL X-RAY REQUIRE RADIATION SHIELDING IN THE WALLS?


In some cases, yes. National Committee on Radiation Protection (NCRP) standards for shielding are incorporated by reference into Missouri state radiation control rules, and the owner of x-ray equipment is responsible for ensuring that the x-ray room or dental operatory area where the machine is used is


properly designed and shielded accordingly.


19 CSR 20-10.190 Requirements for Room Shielding


“The requirements for room shielding shall conform to the requirements defined in the various handbooks published by the [National Committee on Radiation Protec- tion; the most applicable current standard is NCRP Report #145 ‘Radiation Protection in Dentistry.’]”


Depending on x-ray workload, occupancy factors and layout of the room, in some dental offices, additional radiation shielding beyond that inherently provided in construc- tion materials (drywall) is not necessary. Other offices will need additional shielding material (lead sheets or additional layers of drywall.) However, this cannot be adequately determined without an evaluation and/or calculation by a Qualified Expert (QE) in radiation protection.


In years past, proper conformance to ap- plicable shielding standards in new dental offices was presumed by MRCP. However, the shielding standards were not well under- stood, and were not always consistently ap- plied. Beginning January 1, 2014, new dental facilities or existing facilities adding new x-ray rooms or operatory areas must actively demonstrate compliance with the shielding standards.


This means that a new dental office open- ing or an existing practice adding additional x-ray rooms (or converting a room from intraoral or panoramic to CBCT) must have a shielding evaluation by a Qualified Expert. This shielding evaluation is in addition to the requirement of an on-site inspection of the equipment performance by a QE. The evalua- tion must be submitted to the MRCP office for inclusion in the facility’s file.


These shielding evaluations take some time for the QE to prepare, so it is important when dentists begin initial planning for a new office or new x-ray rooms, they obtain the consultation services of a QE before the equipment is installed, so that utilization of the equipment is not needlessly delayed. f


For additional questions regarding radiation protection requirements, contact the Missouri Radiation Control Program at MRCP@health.mo.gov or 573-751-6083.


ISSUE 1 | JAN/FEB 2015 | focus 19


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48