Shawn A. Clemenson

Qualified X-Ray
Inspector #164

303.968.7445

FAQs

What type of x-rays do you inspect?

We provide inspections on every type of Dental and Veterinary X-Ray machine.

Which parts of Colorado do you conduct x-ray inspections?

We cover the entire state of Colorado. We are based on the Front Range in the Metro Denver area but have customers throughout the state. We are in the Western Slope area every month.

How often do I need to have my x-rays inspected?

Dental machines are required to be inspected every 3 years with the following exceptions, Dental 3D/CT machines and Dental Handheld Portable machines are to be inspected annually (every year).  Veterinary machines are required to be inspected every 3 years.

Do we need to wear x-ray dosimeter badges even if we are now taking digital x-rays?

  • The short answer to this question is "Yes." The reason is that the Colorado State Regulations covering this topic are very clear.
  • RH 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.

We used to badge but no one was getting any exposures so we stopped. Do we have to start again?

  • The short answer to this question is "Yes." The reason is that the Colorado State Regulations covering this topic are very clear.
  • RH 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.
  • Occupational Dose Limits. Click here.

I heard we can stop using radiation monitoring badges or get a waiver. Is that allowed?

Yes, but only if your office is in possession of a current signed waiver issued by the Radiation Monitoring Division.To obtain a waiver you must follow the request procedure correctly.

RH 4.18.3.1 (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 send a letter to the State requesting a waiver from continued monitoring. This is a request only and a 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 it in a safe place at your office and be able to show it to the inspector upon request.

Are there special monitoring requirements if we use a handheld x-ray machine?

Yes there are. RH 6.3.3.10 (2) states, "Each operator of portable hand-held x-ray equipment shall wear whole body and extremity personnel dosimetric monitoring devices." In other words each operator who uses a handheld x-ray machine must wear both a whole body badge and an extremity badge (commonly known as a "finger badge") when making an exposure.

What about handheld x-ray machines? Are all of them allowed?

Currently, the Aribex Nomad and the Gen-Ray Zen-PX2 are the only handheld x-ray machines I know are FDA approved for use.  Be very careful if purchasing online as there are reports of ILLEGAL, non FDA approved machines showing up for sale on line.

Here are the regulations specifically addressing these machines:
  Handheld Machine Regulations.pdf

What is ALARA and what are we responsible for?

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 is by decreasing the length of Time of the exposure, increasing the Distance from the exposure and using adequate Shielding from the exposure. This pertains to both the patient as well as the operator and staff. RH 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. RH 4.5.1 states that you need to properly document that all of the x-ray operators have reviewed ALARA in your office.

Radiation Division's view on ALARA. Click here.

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

I am getting a notice from the state Radiation Program that says I have an inspection due on an x-ray we got rid of last year. What should I do?

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 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. Specifically, you need to fill out form R-61 Disposition of Machines and send it in by mail or fax. 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 a copy of the form and the instructions on how to fill it out.

Intra Oral Test Phantom.

DentX Step Wedge  p/n 9992440015  Cost is about $24.00 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.



end faq

KEEP THOSE QUESTIONS COMING! WE'LL POST THEM AS WE RECEIVE THEM.