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Learn about the regulatory changes, definitions, requirements, and guidelines for CT installations from health physicist John Ferris on December 10, 2010.
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Ionizing Radiation RulesPart 15Computed Tomography Installations John Ferris, Health Physicist Manager, Region II Michigan Department of Community Health Radiation Safety Section December 10, 2010
Administrative Rule Process • Administrative Procedures Act (APA) • State Office of Administrative Rules (SOAHR) • www.michigan.gov/dleg • 2009-040-CH • Legislative Service Bureau (LSB) • Request for Rulemaking (RFR) • Regulatory Impact Statement (RIS) • Public Hearing • Joint Committee on Administrative Rules (JCAR) December 10, 2010 2
Timeline • July 20, 2009 – SOAHR approves RFR • Late summer 2009 – met with stakeholders • February 2010 – SOAHR approved first draft • February 2010 – SOAHR approved RIS • May 18, 2010 – first public hearing • November 1, 2010 – second public hearing • November 2010 – final(?) draft submitted • December 2010 – JCAR report submitted • SOAHR/LSB/JCAR December 10, 2010 3
Changes (draft 1 vs draft 2) • Effective date of the rules • Definitions • CT Operators • Medical physicist • Enclosures & Conditions of operation • Reporting CT medical events • QC rules grouped together • Record/report retention rules grouped together • Changes were made for clarity, flow • Rule numbers were updated December 10, 2010 4
Changes (draft 2 vs draft 3) • R 325.5703(c) – “CT medical event” definition • R 325.5703(h) – “SPECT” definition • R 325.5711(6) – Observation window requirement • R 325.5715(5) – Notification of a medical event • R 325.5717(a) – Quality control program • Grammatical changes December 10, 2010 5
Guidance • Guidance for facilities • Guidance for inspectors • RSS inspections 6 December 10, 2010 6
R 325.5701 Purpose and scope • Part 15 - CT used for diagnostic imaging in the healing arts • Exemptions • Low powered CT units < 5 kilowatts • PET/CT and SPECT • Therapy simulation • Intra-operative guidance tomography • Other applicable IRR • CON CT review standards December 10, 2010 7
R 325.5703 Definitions • 21 C.F.R. 1020.33, “Computed tomography (CT) equipment” (June 10, 2005) • “Annual” – 12 consecutive months December 10, 2010 8
R 325.5703 Definitions “CT medical event” means an unintended event where a physician determines that actual damage has occurred to an organ or a physiological system of an individual due to or suspected to be due to exposure to diagnostic radiation from a CT scanner.
R 325.5703 Definitions • “Medical physicist” means a person trained in evaluating the performance of CT scanners, related equipment, and facility quality assurance programs and who meets the requirements in R 325.5707. • “Radiologic technologist” means an individual specifically trained in the use of radiographic equipment and the positioning of patients for radiographic examinations and who meets the requirements in R 325.5705. December 10, 2010 10
R 325.5703 Definitions • “Traceable to a national standard” means an instrument is calibrated at either the national institute of standards and technology (NIST) or at a calibration laboratory that participates in a proficiency program with the NIST at least once every 2 years and the results of the proficiency test conducted within 24 months of calibration show agreement within ± 3% of the national standard in the appropriate energy range. December 10, 2010 11
R 325.5705 CT operators • Take effect 6 months • Licensed physician OR • Radiologic technologist • ARRT registered OR • CAMRT registered AND • Documented 20 hours of training and experience OR • Have the advanced ARRT CT certification • Continuing education • Compliance with ARRT requirements • Include credits pertinent to CT. December 10, 2010 12
R 325.5707 Medical physicist • Board certified • ABR • ABMP • CCPM OR • MS or PhD • Accredited institution • Required courses • 3 years experience in CT OR • Exemption December 10, 2010 13
R 325.5707 Medical physicist • Continuing experience • Continuing education • Reestablishing qualifications December 10, 2010 14
R 325.5709 Equipment requirements • 21 C.F.R. 1020.33 “Computed tomography (CT) equipment” (June 10, 2005) • Maintain compliance with 1020.33 December 10, 2010 15
R 325.5711 Enclosures Similar to Part 7 No “40” inch exposure switch rule Observation window “shall have a lead equivalence at least equal to that required of the control barrier”
R 325.5713 Conditions of operation Scanning protocols Checking techniques or doses Document/investigate high doses Operated from a shielded position Pb aprons or whole body barrier Exposure records on file
R 325.5715 Report and notification of a CT medical event Reporting requirements similar to NRC Department notified within 15 days Patient/referring physician notified within 1 wk Investigations
R 325.5717 Quality control program Effective 6 months Medical physicist supervision Quality control program Image quality Patient radiation dose Personnel radiation protection Compliance with this part Ongoing quality control Written procedures Corrective action Frequency Assigned to a technologist or qualified individual
R 325.5719 Initial and annual medical physicist performance evaluations Initial evaluation – before use on patients Annual evaluation Calibrated dosimetry system Recommended tests/evaluations Reports Summary of performance evaluation Recommendations for improvement Dosimetry system and calibration date Provided in 30 days
R 325.5721 Records and report retention Operators and medical physicists Kept current during employment Until the next inspection for former employees CT medical events – 7 years Survey reports – 5 years Ongoing quality control – 2 years
Summary • Descriptive vs prescriptive • Final? • Stakeholder involvement • Thank you • Questions? December 10, 2010
Radiation Safety Section Contacts • Lansing • Phone: (517) 241-1989 • Fax: (517) 241-1981 • Website: www.michigan.gov/rss • Email: rssinfo@michigan.gov • Detroit • Phone: (313) 456-4660 • Fax: (313) 456-4676 • Email: jeferri@michigan.gov December 10, 2010 23 23