The CDPHE has proposed several changes and additions to the x-ray regulations. Many of these changes directly affect chiropractors. From now until Aug 29th 2018 they are accepting feedback and I will be happy to pass along any comments you may have along with my own.
I have gone through the proposed changes with a fine-tooth comb and have pulled out what will directly affect chiropractors. I will briefly list them below. If you want more detail, there is a link to a more detailed document at the end of this blog. You may also email me firstname.lastname@example.org with questions or feedback.
1. All digital x-ray systems will require an initial evaluation by a Registered Medical Physicist (RMP). Currently, a new x-ray installation requires a shielding design done by an RMP. This will be an additional step when you have a new CR or DR system installed, whether in a new x-ray room or as an upgrade to your existing set up. I am an RMP, and I am already preparing for the demand once this goes into effect.
2. Facilities will be required to have a documented procedure to verify patient ID and correct body part before their x-rays. While I believe this makes sense in a big department with x-ray techs getting patients from waiting rooms, it only adds a layer of paperwork for a chiropractor who does his/her own x-rays.
3. There will be established rules for what needs to be included in a quality assurance (QA) program for your digital x-ray system. Most of the items will be easily taken care of, but they will require some work to get your program in compliance. One of the changes will require documentation of every time you repeat or reject an image and retake it. This could be burdensome on chiropractic offices.
4. You will need to have a shielding design on file with a floor plan, equipment configuration, and documentation that the shielding design was followed. It is already a regulation that you need to keep the shielding design on file. Most shielding designs will already have a floor plan and equipment configuration, but I think very few chiropractors have a document that says the shielding design was followed during construction.
5. Your radiation safety program will need to have a policy on when and where patient shielding is to be used. This may be some initial work to document what you are already doing in terms of patient shielding.
6. Patient shielding materials (waist, thyroid shields, etc.) need to be inspected annually for tears and holes, and this needs to be documented. This can easily be added to the annual inspection for your x-ray machine but adds some work for the inspectors.
7. The radiation safety program will also need to contain a QA program for the imaging system, documentation of an annual review of this program, and the establishment of acceptable ranges for exposure indicators (mentioned above with the RMP evaluation of digital systems).
8. Finally, the brightness of the light field that shows where the x-rays are going to go has been more clearly defined. You may see your inspector requiring new or more powerful light bulbs in the head of the x-ray machine. These light bulbs are usually very inexpensive and quick to replace.
Click here for a more detailed description of the proposed regulations mentioned above and my comments on what can be sent to the state for feedback.