I practice in Missouri and to help my fellow practitioners in the state I am posting a letter I received this week from the Missouri Dental Association regarding radiological inspections. If you are a Missouri practitioner, please read the following carefully as the MDA has done a wonderful job of explaining the laws and procedures.
This email is in regard to Radiation Inspection Surveys that the Missouri Radiation Control Program (MRCP) requires dentists to have performed on their machines every six years (and annually for CBCT machines).
This is not new information, but a reiteration of information the MDA has shared previously. Additionally, the MRCP alerted all existing facilities of this in December 2012 and periodically since then.
- The state of Missouri (19 CSR 20-10.050, page 5) actively enforces for all facilities the performance of radiation inspection surveys performed by Qualified Experts.
- For many years, as a public health service, the MRCP was able to directly employ radiation safety professionals to perform inspections. However, due to changes in priority and lack of staff, as of January 2014 responsibility for providing these inspections has transitioned back to the equipment owners. This transition was originally announced by letter in December 2012. To minimize impact, this transition is taking place incrementally over several years.
- Effective January 1, 2014, it became the responsibility of the owner of x-ray machines to provide for both initial and periodic inspection of x-ray machines, and to ensure radiation shielding is adequate, through use of MRCP-approved Qualified Experts (QEs) in radiation safety.
We are sending this information again now because many MDA members will begin receiving notices that their inspection survey is due.
Until now, only dentists who were opening new offices, moving, adding additional operatories/rooms or adding CBCT have had to get surveys since January 1, 2014. Beginning in 2017, all other facilities already in existence on January 1, 2014 will be moved into the rotation by MRCP to receive the survey notices. The implementation is being done incrementally. Existing facilities starting in the rotation in 2017 will be completed over a 6-year implementation period (meaning 1/6 of facilities will be inspected for the next six years, and this amount is divided over 12 months; therefore about 30 dentists/month statewide starting in 2017).
Additionally, you may receive marketing materials from Qualified Experts (those companies who perform the inspections) implying you need to make sure you are in compliance before the end of the year. You should not let these marketing pieces alarm you, especially because your inspection due date may not be for many more months or even years from now. It is the responsibility of the dentist to have the survey performed by the required date, however, QE companies do not know these dates, and if they send marketing materials, it is only to make you aware of their services.
Here is a quick summary of key points that were included in the 2014 Focusarticle. You can read the full article by clicking here (including a full list of CBCT references).
- Dental facilities with x-ray machines must now hire Qualified Experts (QEs) in radiation safety, approved by the MRCP to perform initial and periodic surveys (inspections).
- The QE will evaluate radiation safety of the facility, usually to include machine performance, shielding and personnel monitoring. The QE will send evidence of the findings to the MRCP for any necessary follow up.
- These inspections must be done whenever new facilities open or new x-ray rooms are added, and for existing facilities, prior to the QE due date assigned to your facility by MRCP. Most of these due dates will be from 2017-2022, then every six years thereafter. This due date already has been mailed to your facility. Your facility also will be sent a reminder notice 90 days prior to the due date. Cone Beam CT machines must be inspected annually beginning in 2014.
- If a new x-ray room is added, in addition to the machine inspection, the facility also must demonstrate that radiation shielding is adequate. This can be done by following a shielding plan evaluation by a Qualified Expert or at the time of an initial inspection on the new room prior to routine clinical usage. Click here to read a 2014 Focus article on Radiation Badges and Shielding.
- Repairs of existing equipment or replacement of dental equipment in existing rooms do not require a mandatory survey. However, facilities are encouraged to contact their QE to discuss if additional safety testing may be prudent.
- A QE list is at the MRCP website at http://health.mo.gov/safety/radprotection (see additional comments following). QE survey fees are not set or controlled by MRCP but by private arrangement between QE and facility. Type of equipment, numbers of machines and distance of travel for the QE may all factor into the cost.
Currently, the MDA is determining what it may be able to do to work with the MRCP and QE companies to provide additional assistance and information to members. As our work and information develops we will let all members know.
One action already implemented is that we have worked with the MRCP to provide an even further curated list of QEs, identifying those that most frequently serve dentists; thus decreasing the potential list of those you could call, should your survey be due soon. This list can be accessed at the MDA website Radiation Inspection Surveys FAQ (or access just the PDF list link here).
Related to CBCT inspections, the MDA has CBCT legislation that we’ve been trying to pass for a few years. We feel it is unduly burdensome and are seeking to have CBCT machines moved to the 6-year inspection rotation instead of the annual inspection now required. In the 2016 session, the Senate marooned a few of the bills we hoped to see pass on the last day of session – including the CBCT bill. Therefore, this will again be an MDA legislative priority for 2017. Additionally, the MDA put forth a resolution to the ADA House of Delegates—which was adopted—to have the appropriate ADA agencies review the recommendations for all dental radiographic equipment which will include CBCT.
The MDA will continue to work on this issue to assist members as much as possible and will inform you of any developments. If you have questions, email Melissa Albertson or call 573-634-3436, Ext 103.