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Would your hospital pass a radiation safety inspection?

Pennsylvania Department of Environmental Protection Dennis Ferguson answers your questions about radiation safety.


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Somebody’s hand was exposed during the X-ray process.

Courtesy Dr. Phil Zeltzman

Do you know what the DEP is? Not every state calls it by the same name. In Pennsylvania and some other states, it is known as the Department of Environmental Protection.

Are you aware that you could receive a surprise visit from your friendly local DEP inspector?

We talked to Dennis Ferguson, supervisor of the X-ray and Accelerator Program in Pennsylvania’s Southcentral regional office in Harrisburg. If you do not work in Pennsylvania, you should check the regulations with your particular state regulatory agency.

What is the DEP?

The mission of the state Department of Environmental Protection is to “protect Pennsylvania’s air, land and water from pollution and to provide for the health and safety of its citizens through a cleaner environment.” I am specifically in charge of radiation protection.

Is it advised or required to wear lead gowns while taking X-rays?

Regulations pertaining to veterinary medicine state that anyone not behind a protective barrier (lead shield) or at least 2 meters away from the X-ray tube head and primary X-ray beam needs protective attire.

The gown, apron or glove needs to have 0.25 millimeter lead equivalent attenuation. [A gown wraps around the whole body; an apron covers only the front of the body.]

You also need to ensure that you don’t expose any part of the body except the hands and forearms to the primary beam. 

Even gloved, nobody’s hand should be in the primary X-ray beam.

Courtesy Dr. Phil Zeltzman

Even gloved, nobody’s hand should be in the primary X-ray beam.

If the hands and forearms are required to be in the primary beam (for example, to restrain an animal), they need to be protected by at least 0.5 mm lead equivalent. The regulation does require use of a remote holding device where it’s practical.

Is it true that we don’t need to wear gloves while taking digital X-rays?

Absolutely not; this is incorrect.

Current regulations require gloves when working in the primary beam of the device, and if you have to have your hands in there, you must wear gloves with a lead equivalent of 0.5 mm, whether you use digital or standard X-rays.

Are leaded goggles mandatory?

Leaded goggles are not mandatory, according to [Pennsylvania] regulations. However, if they’re available, by all means, please use them to protect the lenses of your eyes.

Does closing your eyes do anything to protect them while taking X-rays?

Eyelids are not an effective shield. If you’re worried about eye damage, it’s better to wear leaded glasses.

Are X-ray badges mandatory?

In Pennsylvania, if a person is going to receive over 10 percent of a federal annual exposure limit, personnel monitoring is required.

If a facility does not want to use dosimeters, the burden of proof is on the facility to show that personnel exposure will not exceed those limits.

Clinics also have to ensure that no part of their personnel will enter the primary beam of the X-ray machine. It can be done, using remote devices to secure the animal and backing away during the exposure, but it will require discipline --and sedation.

Wearing the proper protective gear, a technician works with a patient in the X-ray room.

Courtesy Dr. Phil Zeltzman

Wearing the proper protective gear, a technician works with a patient in the X-ray room.

These are the reasons using dosimeters is a much simpler solution.

Do you investigate practices based only on complaints, or do you do regular or random visits?

Our inspectors visit clinics approximately once every four years, unless there are complaints or violations. In the latter case, staff may visit more frequently to make sure the facility is staying in compliance.

Our inspectors are allowed to perform unannounced inspections, but most radiation protection inspectors will call to set up an appointment. That’s a courtesy they’ve extended, so if an inspector does call, it is highly recommended to return the call.

Is there a difference in radiation exposure between digital and traditional X-rays?

Digital equipment can produce an image with less exposure. But the trick is to make sure you are getting a good image for the lowest possible exposure.

Some clinics have had digital equipment installed but the source was left set for standard film exposures, which gives a good enough image, but you can do it at a lower exposure.

That’s something some of our inspectors, using a radiographic phantom, can assist with. It is part of what we provide for the fees paid. It saves the personnel exposure, plus it can significantly prolong the life of the digital image receptor.

In some states, it is illegal to be present in the room while taking an X-ray. Why not in Pennsylvania?

In Pennsylvania, occupation of the room is restricted to staff members who are required to obtain the exposure, which allows using the “sedate and hold” procedure if necessary.

Anyone not involved in holding the patient but necessary for the exposure has to be back at least 6 feet (2 m.) or behind a barrier to be out of the primary beam and most of the scatter radiation.

Anyone else needs to be out of the room.

Is it OK for a non-gowned person to stand behind a gowned person to protect themselves from radiation?

As stated previously, anyone not behind a leaded shield or 2 meters away is required to have protective attire.

That’s the regulation, but it also makes sense: The “human shield” could move at an inopportune moment, and getting close enough to be an effective shield involves some serious violation of “personal space.”

Is it legal to have a client in the X-ray room, for example to restrain the pet? Members of the public can only be exposed to 100 mRem of radiation per year. That’s not a whole lot!

For their safety, it’s best to keep them away from the room where the X-ray is being taken, and never restraining the pet.  The AVMA’s Professional Liability Insurance Trust strictly frowns upon clients restraining their own pets anyway, let alone when radiation is involved.

What do you think of the common classic joke, “Oh, I’m done using my ovaries, so I don’t need X-ray protection”?

There are other side effects of radiation exposure besides your gonads, such as radiation dermatitis, skin cancer and cataracts. Even if you don’t mind the risk, someone else might.

What kind of cancers does radiation cause?

They include skin cancers (melanoma, squamous cell carcinoma) as well as leukemia.

Is it true that we receive more radiation from the sun and the environment that from therapeutic X-rays?

People receive a good bit of radiation from the sun and environment, about 310 mRem worth, according to the Health Physics Society, a professional organization of radiation protection personnel.

But that doesn’t mean this should be taken lightly. Radiation exposure from man-made sources is on the rise. Our job in the Bureau of Radiation Protection is to try to minimize exposure from all sources.

What are the three most common infractions you find?

The three most common infractions are late fees, dosimeter issues and machine malfunction.

Late fees are pretty self-evident infractions. It’s how the inspections, the equipment, and the time to assist the registrants are paid for.

Since radiation can’t be seen, felt, smelled or heard, you need some way to determine how much you’re receiving. Dosimeters are a very important piece of the radiation protection equation, and they have to be used properly. For example, you can’t share dosimeters.

If your X-ray machine is malfunctioning, you could be getting poor-quality radiographs, which makes it necessary to repeat exposures, increasing personnel (and patient) exposure.

What are your biggest pet peeves?

People don’t ask us questions!

Sometimes, people work themselves into a noncompliance situation, instead of asking us.

The Bureau of Radiation Protection is not a consulting firm, but our staff can help guide you on how to stay compliant, provide information and give you a list of consultants to assist you.

Veterinarians should take advantage of the department’s wide range of backgrounds so we can think of a solution, perhaps “outside the box,” that keeps them in compliance.

A simple phone call could prevent a lot of our noncompliance issues. The Bureau of Radiation Protection exists to protect public health, so we want our registrants to remain compliant. It benefits everyone.

What do you wish all veterinarians and technicians knew?

Radiation is radiation, whether it’s from a digital or “traditional” film system. There is no “good radiation” or “bad radiation,” there’s just radiation, period.

The problem lies in the fact that we do not know at what point radiation becomes carcinogenic. Therefore, always take the precautions mentioned previously.

How much is the average penalty?

DEP prefers that registrants do not have to find out the answer to this question. We can assess up to $25,000 for a violation, plus up to $5,000 a day for continued violation. Penalties are meant to be a deterrent, and they depend on the culpability and severity of the violation.

Would an inspector ever ask for cash?

They should NEVER ask for cash!

Annual registration fees and fines can be mailed to your Regional Office.

Any final words of wisdom?

For more information, visit here.

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