Joint Subcommittee Recommendation

At the conclusion of its study, the joint subcommittee endorsed legislation to require the licensure of radiologic technologists. The proposed legislation (i) provided for a two-tier licensure to allow full unlimited practice for those who met certain training and competency standards and a limited licensure for those who performed radiographic procedures only on certain areas of the body; (ii) allowed use of currently recognized testing organizations to minimize cost to the state and place Virginia in a better position for reciprocity and endorsement of licensure; (iii) exempted certain individuals who already must receive similar training under the auspices of another board under the Department of Health Professions; (iv) required continuing education; and (v) had a delayed effective date to allow for regulations to be adopted and for individuals to receive the necessary training.

Executive Summary

X-rays were discovered in 1895 and by mid-1896 the harmful effects of these rays on skin were beginning to be noted. (*1) When the potentially beneficial uses of these rays were discovered for use in medical diagnosis and therapy, the usage of the machines expanded as did the number of persons operating such machinery. Initial study and documentation of the effects of the application of ionizing radiation since the beginning of its usage on humans and animals accrued slowly in the first half of this century, but a large amount of scientific evidence has been collected systematically only since World War II. Scientific research in physics and radiation biology has determined that there exists no dose of radiation too small to cause biological damage to the body, including genetic mutations.

To protect its residents, the Commonwealth of Virginia has established stringent guidelines and criteria for occupational licensure of occupations. Previous studies have examined this issue and, while not wanting to leave citizens unprotected but at the same time not impose overly intrusive regulations upon a particular occupation, those studies recommended only registration--the first and easiest level of regulation. A later study, however, opted for certification, or title protection, for radiologic technologists. This study committee felt that both of those systems, while appropriate at those particular times, were insufficient for today's needs and that a higher level of regulation in the form of licensure was necessary to protect the quality of health care in the Commonwealth. The subcommittee also noted that under Virginia law, dental technicians, veterinary assistants, and even individuals who x-ray industrial pipe fittings had to exhibit minimum training and competency standards, while persons who x-ray humans did not.

After reviewing the standards set by the Department of Health Professions for the regulation of a health profession, the joint subcommittee endorsed legislation to require the licensure of radiologic technologists. In so doing, the joint subcommittee, being conscious of the impact which this legislation could have on the cost and provision of medical care, worked throughout the study with various interested groups, including the Virginia Society of Radiologic Technologists, the Medical Society, and the Academy of Family Practitioners. The legislation (i) provided for a two-tier licensure to allow full, unlimited practice to those who met certain training and competency standards and a limited licensure for those who performed radiographic procedures only on certain areas of the body; (ii) allowed use of currently recognized testing organizations to minimize cost to the state and place Virginia in a better position for reciprocity and endorsement of licensure; (iii) exempted certain individuals who already must receive similar training under the auspices of another board under the Department of Health Professions; (iv) required continuing education; and (v) had a delayed effective date to allow for regulations to be adopted and for individuals to receive the necessary training. The joint subcommittee also worked with many groups to assure that training was readily available in the Commonwealth and that programs could be developed to minimize the impact of this training on the provision of medical care, especially in the smaller, rural practices. (Copies of House Bill No. 1300, 1994, and the proposed regulations are found in Appendices 1 and 2.)
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(*1) Samuel Glasstone. "Sourcebook on Atomic Energy." (New York: Van Nostrand Reinhold. New York. 1967. 734).