Frequently Asked Questions
We provide inspections on every type of Dental and Veterinary X-Ray machine including CBCT/3D machines.
We cover a large portion of the state of Colorado. We are based in the Metro Denver area and have customers throughout the state. More specifically we cover the Front Range from Castle Rock north to Wellington, East to Sterling and West to Estes Park. We also cover the I-70 corridor from Denver to Grand Junction. Additionally, we travel to the Gunnison/Crested Butte and Steamboat Springs/Craig areas. We are on the Western Slope every month.
Dental and Veterinary machines are required to be inspected every three years with the following exceptions: Dental CBCT/3D machines and Dental Handheld Portable machines need to be inspected annually (every year). All veterinary machines are required to be inspected every three years.
This annual requirement started in 2010 and has been required annually ever since. This MUST be completed by the office, not the inspector. It is not part of the Certification Inspection that was conducted on your x-ray machine. The Radiation Safety Officer (or their designee) must complete the R-4 online Registration form (click here) and the state will then invoice you for the annual $50 registration fee. The office must then pay it. Not completing this each year will affect any communications you may have with the CDPHE X-ray division. An example would be a denial for a waiver for radiation monitoring because you are not current with your registration.
- The short answer to this question is “Yes.” The reason is that the Colorado State
Regulations covering this topic are very clear.
- 4.18.1 states that “each licensee or registrant shall monitor occupational exposure from licensed or unlicensed sources under the control of the licensee and shall supply and require the use of individual monitoring devices…”
- In other words, each operator of the x-ray units at your facility must wear a film
badge/radiation monitoring device.
- This must continue until or unless you receive a waiver from the CDPHE.
Yes, but you MUST receive a waiver from the CDPHE before you stop monitoring.
To obtain a waiver you must follow the request procedure correctly.
RH 18.104.22.168 (1) states that “Acceptable alternative demonstration that doses will not exceed 10 percent of the annual dose limits in RH 4.61. RH 4.12 and RH 4.13 include submittal to the Department of an acceptable application documenting six months of the use of continuous individual monitoring devices.” In other words, if after 6 months of monitoring, your reports show that every operator is receiving less than 10% of the allowed occupational dosage of radiation, you may then apply to the State requesting a waiver from continued monitoring. This is a request only and granting of a waiver is solely at the discretion of the Radiation Monitoring Division.
Here is the official waiver request: R-400 Dosimetry Request Waiver.pdf
If you receive a waiver from the Radiation Control Division, you must keep the letter in a
safe place at your office and be able to show it to the inspector upon request.
Yes, there are additional safety measures and procedures that must be followed when using a handheld X-ray unit. Click here to read the one-page addendum, Part 6 Appendix 6E.
Currently, there are several handheld x-ray machines that we know are FDA approved for use. If they are FDA approved they will have a label on the unit stating: Meets the standards prescribed in the Code of Federal Regulations, Title 21, Chapter I, Subchapter J. Be very careful if purchasing online as there are reports of ILLEGAL, non-FDA approved machines showing up for sale on line. These non-approved machines are illegal to possess or use at both the Federal and State level.
ALARA stands for As Low As Reasonably Achievable. It is a concept of keeping all exposure risks to a minimum amount needed to properly diagnose by way of an x-ray exposure. The best ways to minimize the risk are by decreasing the length of Time of the exposure, increasing the Distance from the exposure and using adequate Shielding from the exposure. These pertain to both the patient as well as the operator and staff. 4.5.2 states “The licensee or registrant shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the public that are as low as is reasonably achievable (ALARA).” This means your office needs to employ ALARA as part of the routine way you conduct x-ray exposures.
RH 4.5.3 states “The licensee or registrant shall, at intervals not to exceed 12 months, review the radiation protection program content and implementation.” This means that once a year everyone who takes x-rays needs to review ALARA and any x-ray policies in place at your office.
RH 4.5.1 states that you need to properly document that all x-ray operators in your office have reviewed ALARA annually.
Here is a suggested review of ALARA principles you can use to meet your annual requirement as
well as a sheet to document the event. ALARA.pdf
- First, your service company who removed the x-ray unit should have coached you to fill out the proper form and send it in to the state so the Radiation Program would know that you are no longer using that x-ray. While it is the x-ray owner’s responsibility to comply with notifying the state, the Radiation Program has asked all Certified Service Providers to help their customers by coaching them on what to do when they get rid of an x-ray machine. Specifically, you need to fill out the online form R-61 Disposition of Machine. The state will then send you a letter confirming you are no longer using or in possession of that machine. Keep the letter for your records.
- Here is the link to the online form.
DentX Step Wedge p/n 9992440015 from your dental parts supplier. This is a great tool for the office. Place the wedge on the sensor or film pack and take an image with your x-ray at the typical settings like you normally would. If you can see all 10 shades of grey then your setting on the x-ray is right on or possibly a timer setting up or down for best image quality.