Checklist To Prepare For Your Next CDPH-RHB Equipment Inspection (Last Update 25-August-2020)
I've tried to be as comprehensive as possible. If you note anything missing from my list, please email me and I will add it.
1) Document And Physical Review
Display Of Documents/Certifications/Signage/Posting
- CDPH-RHB Radiography X-Ray Supervisor & Operator permit is posted and CURRENT.
- CDPH-RHB X-Ray Technologist or Limited Technician permits (if any), including any specialized training, are posted and CURRENT.
- Certificates for x-ray continuing education for the last CDPH-RHB Radiography Supervisor & Operator permit renewal period available to show the health inspector.
- CDPH-RHB X-Ray facility (tube/machine) registration/permit is posted and CURRENT.
- Chain of supervision: responsibilities and obligations of Supervisor if technologists are employed to take x-rays.
- Policy for student supervision if applicable.
- "Caution X-Ray" warning sign must be posted outside every entrance to an x-ray room.
- Possible pregnant female sign posted.
- Any notice of violation involving radiological working conditions or any order issued pursuant to the Radiation Control Law and any required response from this facility.
- Display of "Laws and Regulations": A current copy of the California Radiation Control Regulations (California Code of Regulations, title 17, and 10CFR20 Standards For Protection Against Radiation) must be posted or must be readily available to office personnel. This can be a hard-copy Barclay's manual or you can substitute internet access (go to INFORMATION RESOURCES, REQUIRED USER ACCESS TO CCR TITLE 17). If you are using a hard-copy Barclay's manual, it is supposed to be CURRENT (include any recent regulation changes). If it is older than any recent changes to the regulations, the health inspector may issue a violation. Internet access is CURRENT. I have a clean one-page internet access document for all required regulations, contact me.
- "Notice to Employees" must be posted in an area frequented by employees. A current copy of Department Form RH-2364 "Notice to Employees" may be downloaded free from the CDPH-RHB website. This and most other required documents are available at: https://oal.ca.gov
- Radiation Safety Instructions (not the same as your radiation safety program): includes potential health problems associated with exposure to ionizing radiation, appropriate response to warning or malfunction, procedures to minimize exposure and safe operation of the x-ray machine. The Radiation Safety Instructions may be the operating manual that comes with the X-ray machine if it includes safety procedures. It should be posted with the x-ray machine so it can be accessed by the operator during work hours. If safety procedures are not included in the operating manual, they must be developed.
- Records of proper reporting of any radiation-related events/incidents, kept indefinitely.
- Notification to patient & referring physician.
- Notification to the RHB in a timely manner and any corrective actions taken.
Radiation Safety Program (Radiation Protection Manual)
- Radiation Safety Program suitable for a small office is developed and implemented with proof of annual review (signatures) with staff. This includes all policies and procedures appropriate to the modality employed..
- I am selling one for $22.00 (go to submenu under INFORMATION RESOURCES: SMALL OFFICE RADIATION SAFETY PROGRAM to read about it. You can purchase my RSP, now in its 8th edition, by following this link: PURCHASE RSP
- Dosimetry program for occupationally exposed persons, including all past and current records, monitoring, employee notification, records kept indefinitely. If personal dosimetry is not being used, be prepared to justify to the health inspector (with data) why you are not using it.
- Pregnant worker policy for declared pregnant workers with special monitoring policy.
Radiation Protection Of Personnel
- Protective lead apparel including proper care (stored correctly, do not fold) and use policy. Available onsite should be at least one full-length lead apron plus a pair of gloves, both 0.5mm lead equivalent.
- Pregnant worker policy.
- Patient restraint (holding) policy: If holding of a patient during radiography is necessary, and a mechanical restraint device is not available, a member of the family (preferably the father) is recommended. Operators/employees may hold a patient only in an emergency, never repeatedly. Holders must wear leaded apparel (apron and gloves). Note that most over-exposures to operators occur during patient holding.
- Results of all machine calibrations and maintenance.
- Initial radiation protection survey including stray radiation measurements, facility shielding to meet all County and State regulations regarding the operator, patient and public.
General Supervision & Training Requirements for Radiologic Technologists
- Only applicable if you are supervising technologists to take your x-rays.
- Chain of supervision including responsibilities and obligations of Supervisor if technologists are employed to take x-rays.
- Orientation, basic training of technologists on your equipment.
- Policy regarding supervisor orders (requisition Rx) for x-ray exams and procedures.
Overall Image Quality, Radiation Dose and Quality Assurance
- Facility name and address, patient name, DOB, age, gender, x-ray date, studies etc. clearly marked (typed is better) on all films or properly saved into each DICOM file.
- Evidence of collimation and gonad shielding on your images: inspectors will check your analog films and open your PACS to inspect.
- Correct use of Right and Left film marking with operator ID. Annotating (adding) right and left onto your images using your DICOM browser software after-the-fact is discouraged (not recommended) and could result in a warning or violation. Use lead markers placed inside the collimator light field. Lead x-ray markers, including position indicator markers with operator initials, flex, exten, int, ext, etc. can be purchased at Amazon.com or do a Google search, for about $30/pair.
- Technique factor wall chart (or built-in to the system) with values optimized for high optimum kVp radiography, correct SID/FFD and patient thickness in cm as measured by a caliper.
- Digital systems: histograms from pre- and post-processing images will be retrieved from your PACS by the health inspector for analysis of radiation dose. CDPH expects the supervisor to have a copy of the manufacturer operator manual and that the supervisor understand the exposure indicator system used by the digital x-ray system he is using. The supervisor is responsible for preventing dose creep by following an optimized x-ray technique chart/system and keeping track of exposure indicator values over time to ensure that they are not increasing (dose creep).
- Film/Screen systems: optimum practices for wet processors and chemistry, film & screen compatibility and known film/screen system speed (not less than 400).
- QC tests on your wet processor performed at required frequency: measurements of developer temp, density difference, mid-density and base plus fog levels, within normal limits, for all days x-rays were taken, and plotted correctly on your Processor Control Chart. In addition, quarterly Fixer Retention and semiannual Darkroom Fog test records will be checked. The inspector will ask to see your QA equipment plus your 5-day average and processor control charts. He may also ask to see sensitometric films/strips, fixer (thiosulfate) retention test kit and test films/strips, actual films used for darkroom fog test, and even your x-ray log book to compare to your processor control chart.
- Records of wet processor QC testing maintained for one year.
2) Equipment Testing
- During equipment testing, your office user/operator/supervisor must be present to operate the tested equipment. Verification of the accuracy of at least 10% of the x-ray tube inventory and assuring proper technique is being used are assessed in regards to radiation safety.
3) Closing Interview
- During the closing interview, doctors will be informed of any "items" that were found during the inspection. If any violations are found during the inspection, doctors will have 30 (or 35) days from the date you receive the violation(s) in writing to respond.
- Even if your office receives several violations, your office is not likely to be "shut down" from taking x-rays -- unless the inspector sees a clear and present danger to the public. Inspectors are intelligent trained professionals doing their jobs to protect the public from excessive radiation exposure and improve image quality.
- Listen closely to your inspector. I have spoken with doctors many times after their inspection concluded, and then a week later after their written report arrived. Some doctors who thought they passed with no violations, were surprised to find out from their written inspection report that they had several violations. Either the doctor was not paying close attention to what the health inspector said, or the health inspector was not firm enough with his findings to the doctor. Wait for the final report to arrive before celebrating!