HD24 - The Need for the Regulation of X-Ray Technicians

  • Published: 1987
  • Author: Department of Health
  • Enabling Authority: House Joint Resolution 12 (Regular Session, 1986)

Executive Summary:
The Virginia Council on Health Regulatory Boards (CHRB) has studied whether operators of x-ray equipment in health care settings should be regulated in the Commonwealth. This study expands and includes an on-going study of whether radiologic technologists, a special class of x-ray equipment operators, should be regulated. In addition, the Council addressed other concerns of HJR 12 related to radiation safety: (1) whether there should be specific minimum education, examination, or continuing competency requirements for x-ray technicians who operate under the supervision of physicians, podiatrists, chiropractors, dentists, or veterinarians; (2) whether initiation of accreditation based on work experience is feasible; and (3) whether three distinct classes of x-ray technicians for dental, medical, and veterinary practice should be established and regulated.

The Council study used six formal criteria adopted in 1983 for evaluating whether health professions should be regulated. The most important of these is the determination of whether a risk for harm to the public health, safety, and welfare is created by the unregulated practice of a health occupation.

The study found that there is a risk for harm to the public from overexposure to ionizing radiation and from other problems resulting from faulty x-ray equipment, improper operating procedures, and/or unqualified operators; however, existing Department of Health regulations governing ionizing radiation safety would provide public protection if fully enforced. While these regulations specifically address safety standards for x-ray equipment, procedures, and operators, enforcement has focused almost solely on equipment safety. Licensed practitioners and administrators who are required to register x-ray equipment with the Department of Health are not always aware of their responsibility to ensure that operators under their supervision are "instructed· in safe operating procedures and competent in the safe use of equipment" as required by Department of Health regulations.

The Council recommends that the least restrictive form of occupational regulation--a registration program for x-ray equipment operators--be established and operated by the Department of Health. This method of regulation provides public protection while avoiding the costly effects of more restrictive occupational regulatory schemes (certification or licensure). Properly implemented, a registration program can provide public assurance that x-ray equipment operators are competent in the safe use of equipment, as they are now by regulation required to be.

Since radiation safety is equally a concern of the Department of Health and the Department of Health Regulatory Boards, the Council recommends that the Secretary of Human Resources appoint a special joint task force involving representatives from both departments to oversee implementation of the registration program and to study and recommend any appropriate standards that should apply to the registration program. This task force should also study other problems related to safe operation of x-ray equipment and recommend approaches to increased public safety for implementation by the Department of Health and the Department of Health Regulatory Boards. Finally, the Council recommends that the Secretary of Human Resources instruct this task force to prepare a report on its activities and accomplishments for the 1988 Session of the General Assembly.

The costs associated with the operation of the task force can be absorbed from existing revenues of the Department of Health and the Department of Health Regulatory Boards. The costs associated with implementing and operating a registration program for x-ray equipment operators should be offset by registration fees charged for obtaining permits for x-ray equipment operation. Since the Department of Health now maintains a structure for the inspection and permitting of x-ray equipment, the cost of integrating an operator registration program can be held to a minimum.