As I mentioned in our previous post, "The 'Sweet 16' Of Radiology Violations" this has been a topic conspicuously absent among our Dental Compliance articles…and I've taken it upon myself to remedy that situation! So, we're going to take a closer look inside Radiology Compliance and in this post help you try to decipher the spider web of regulations.
Most states have radiation safety compliance requirements, along with a state agency to oversee compliance. In states with no such rules or regulatory agency, you've always got the Federal OSHA regulations concerning safety requirements (29 CFR 1910.1096). Whether state or federal, these regulations define exposure limitations, establish precautionary measures and monitoring requirements, specify audible signaling and signage (posting) requirements, and prescribe recordkeeping requirements.
In my home state of Texas, we are what's known as a "State Plan State" meaning the Federal government has approved the state’s regulations as being at least as restrictive as Federal law. As is usually true, state laws can be more – but not less – restrictive than the Federal laws (except, for example, Washington and Colorado’s regulated marijuana laws). In nearly every instance where the state and federal laws conflict, the stricter law will prevail.
Depending upon where you practice, your state regulations could cover everything from registration requirements and fees to allowable uses of Dental X-ray machines, dose limits, employee notice posting, use of technique charts, X-ray controls, timer accuracy, the physical security of X-ray machines, tube stability, inspection procedures, even testing and recordkeeping requirements.
Regardless of the exact nature and degree of oversight within your particular state regulations, most states have an agency assigned to oversee Dental offices’ compliance with radiation safety requirements. In Texas, this agency is known as the Department of State Health Services – Radiation Control Program. Historically, the DSHS-RCP, has been pretty easy to deal with. Dentists submit their registration applications and pay their annual fees, every five years the state inspects the office either remotely or in person…no fuss, no muss. Once in a blue moon, the inspections yield a violation. DSHS sends the violating Dentist a "nasty-gram" with instructions to correct the violation, they collect a fine and everyone goes about their business.
Before we move on, it is important to note the State Board of Dental Examiners also has regulations regarding Dental X-rays (SBDE Chapter 113 – Requirements for Dental Offices). For instance, did you know Dentists (and auxiliaries) are required to ALWAYS use a lead or non-lead apron AND thyroid collar on patients while exposing X-rays? The only exception is “where it is necessary to image areas concealed or obstructed by a thyroid collar.”
In my experience, there is a lot of misconception and confusion about this. Many Dental suppliers are telling Dentists that aprons are not required. I am not sure what regulations they have consulted, but it simply is not correct. What’s more, this requirement holds true even for Dentists using digital X-rays.
And this is just the tip of the X-ray "iceberg!" You use radiographs in your practice to get an accurate picture of what's really going on deep inside your patients' teeth…don't your practice radiology compliance efforts need the same in-depth scrutiny?
As Dentists, prevention is your watchword with your patients. You've seen what happens when they neglect proper oral healthcare and regular vigilance. They can either invest in that proverbial ounce of prevention or end up paying you for a pound of cure! Isn't it time to practice what you preach? Investing in compliance prevention now, can save you thousands – or even tens of thousands of dollars in state and Federal violation "cures." This choice is yours… Ask yourself today, can MY radiology compliance procedures withstand the X-rays of regulatory inspections?