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DEQ.utah.gov -Utah Department of Environmental Quality

Division of Radiation Control

Role of Qualified Experts

UTAH RADIATION CONTROL BOARD POSITION STATEMENT - adopted October 5, 2001

The Role of Independent Qualified Experts in the X-Ray Inspection Program

At the June 1998, Utah Radiation Control Board meeting, the Board voted to move forward with an Advanced Notice of Rulemaking involving some essential changes in the conduct of the Division of Radiation Control's x-ray inspections. One of the changes discussed in the Advanced Notice was the role of qualified experts (medical physics consultants). The rulemaking change proposed that qualified experts would no longer be used as State inspectors, however qualified experts may act as facility consultants. The program change was necessitated by an identified gap in statutory authority allowing qualified experts to act as State inspectors.

During the 2001 legislative session, statutory authority was granted to the Utah Radiation Control Board to develop rules to authorize independent qualified experts to conduct inspections of x-ray facilities registered with the Division. During April - August 2001, representatives of the medical physicists community in concert with the Utah Hospital and Health Systems Association (UHA) met to develop rules. The framework for the rules allows for registration of independent experts that meet minimum qualifications to conduct radiation safety inspections at registered x-ray facilities for the Division. The framework of the rules also promotes the utilization of the joint resources of qualified experts and Division inspectors to conduct inspections of Utah hospitals.

The Division is committed to ensuring that this new inspection efforts meets the needs of the qualified expert and Hospital stakeholders. The Division does not intend to make the inspection process duplicative or burdensome for the facility and its patients. However, the Division has an inspection responsibility to ensure that proper radiation safety practices occur with the use of x-ray units throughout the state. As such, the Division will conduct limited verification inspections of hospitals every three to five years dependent on compliance history. The Division will work closely with the UHA to ensure that the inspection process is periodically evaluated and, if needed, adjusted to address issues of concern of the Division, the qualified experts, and/or the UHA The verification inspection process will include a notification letter from the Division at least 30 days in advance to the facility outlining the scope of the inspection

The role of medical physics consultants is of value in the conduct of Division of Radiation Control x-ray inspections. Since the inception of the x-ray machine inspection program, there has been a valuable and long-term relationship between qualified experts and the Division. The rulemaking change is not intended to detract from or supplant that long-established relationship. The Division of Radiation Control recognizes that because of their unique skills and training, independent qualified experts enrich the Staff's routine inspections. By this position statement, it is the intent of the Utah Radiation Control Board to also recognize the past contributions of qualified experts, and affirm the Staff's continued acceptance of work performed by registered qualified experts in the x-ray machine inspection program.

As indicated in the October 2, 1998 Board Position Statement, a modification to that position statement should occur if there is a change in the working relationship between the State and the medical physics consultants. As such, this Board Position Statement amends and supersedes the Position Statement of October 2, 1998 concerning the role of qualified experts in the x-ray inspection program.

This position statement was passed unanimously by the Radiation Control Board at the October 5, 2001 meeting.

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