REQUIRED SMALL OFFICE RADIATION PROTECTION PROGRAM aka Radiation Safety Program (Last Update 14-April-2022)
The following violation appeared on a CDPH inspection report in 2013 and was one of the first I became aware of:
"Code of Regulations, title 17, section 30253 (a) incorporates certain sections of title 10, code of Federal Regulations, part 20 by reference more specifically, CFR 20.1101 (a) requires each licensee to develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part.
Contrary to the above, there was no evidence that a radiation protection program exists." (verbatim from the report)
This represents the violation of a long-existing CCR Title 17 statute that was previously not enforced for small offices. This old statute applied to any facility with a radiation source. Large complicated radiation protection manuals have been required in hospitals and large installations for decades. In October 2012 the new small office QA regulations for wet processors went into effect, and I noticed its first enforcement in early 2013. Those were chaotic times. Shortly thereafter CDPH began enforcing the old requirement for a radiation safety program in small offices. Enforcement was sparse and random in 2013, but did increase slowly over the ensuing years until by 2017, not having one would likely result in a violation. In 2013 I had several conversations with the inspection compliance chief at CDPH-RHB (who said enforcement would increase), several health physicists in administrative positions at RHB, then over the years a few health inspectors and doctors who got violations. Having a radiation safety program and renewing annually with your staff (internal audit) is just another small cost of doing business. Doctors with x-ray machines must obtain a small office radiation safety program (manual) to show the CDPH health inspector when asked.
Since 2013 doctors have been price-gouged for $100.00+ to get the required "radiation protection program suitable for a small office aka radiation safety program". Most doctors paid that and more, because there was no template out there for small offices (including Chiropractors) to use, and information needed to create one was hard to find and assemble into a usable document.
Several years ago I created a small office radiation safety program that was 8 pages long and comprehensive enough to pass all inspections. It is currently in its 8th edition, 9 pages long, considerably improved and easy to customize to fit your office. It comes in two versions designed for either digital or film/screen image receptors. It is compact, designed for the small office, and has been used by DCs as well as MDs, and most other licentiates. It includes all the required elements: organization & administration, ALARA program, dosimetry program, radiological controls, emergency exposure procedure, record keeping & reporting, reports to individuals, employee training, QA programs & internal audit procedures. It has always passed inspection. If your office gets cited for not having a small office radiation safety program, I will send you mine for the nominal cost of $22.00. Do not mistake this low price for low quality. Browse to CONTINUING EDUCATION, REGISTER & PAYMENT, click directly on the lower blue button/bar, select Radiation Safety Program $22.00 USD. Note that there are THREE choices for RSP: 1. a program for digital x-ray systems (both CR & DR), 2. a program for film/screen (chemical film processing) systems and 3. a program for DEXA machines. Please choose the one that matches your office. As soon as I receive notice, I will email your new RSP directly to you.