From the OSHA.gov webpage:
“ While everyone is exposed to natural background radiation, workers may also be exposed to ionizing radiation in workplaces with radiation sources. These radiation sources can pose a health risk to workers if not properly controlled.
Occupational settings with ionizing radiation sources include:
- Medical and dental offices (e.g., X-rays).
- Hospitals and outpatient treatment centers, including specialty departments in:
- Radiology (e.g., medical X-rays and computed tomography (CT) scans).
- Nuclear medicine.
- Radiation oncology.
- Interventional fluoroscopy or radiology.
- Cardiac angiography.”
In addition to the OSHA regulations there are other agencies that may have jurisdiction over your practice when it comes to ionizing radiation
The Nuclear Regulatory Commission (NRC) regulates exposure to radioactive materials. So if your practice includes nuclear medicine you are subject to the rules of the NRC
OSHA requires employers to protect workers from exposure to ionizing radiation sources that are not regulated by the NRC or other federal agencies, such as X-ray equipment, some accelerators, incidental accelerator-produced radioactive materials, ion implanters, and some naturally-occurring radioactive material (NORM).
In addition to NRC and OSHA, many states have additional rules when it comes to Ionizing Radiation. OSHA State Plans have OSHA-approved standards and enforcement programs that are at least as effective as federal OSHA's. The State Plans may have more stringent requirements for occupational exposures to ionizing radiation when compared to federal requirements.
The OSHA Standards are:
- No employer shall possess, use, or transfer sources of ionizing radiation in such a manner as to cause any individual in a restricted area to receive, in any period of one calendar quarter from sources in the employer's possession and control, a dose in excess of the following limits:
- Whole body: head and trunk; active blood-forming organs; lens of eyes; or gonads: 1.25 rem per quarter
- Hands and forearms; feet and ankles: 18.75 rem per quarter
- Skin of whole body: 7.5 rem per quarter
- An employer may permit an individual in a restricted area to receive doses to the whole body greater than those permitted above, so long as: during any calendar quarter, the dose to the whole body shall not exceed 3 rem; and the dose to the whole body, when added to the accumulated occupational dose to the whole body, shall not exceed 5(N-18) rem, where “N” equals the individual's age in years at the individual's last birthday; and the employer maintains adequate past and current exposure records which show that the addition of such a dose will not cause the individual to exceed the amount authorized in the standard.
- No employer shall permit any employee under 18 years of age to receive in any period of one calendar quarter a dose in excess of 10 percent of the limits specified in the first bullet point above.
- Every employer shall supply appropriate personal monitoring equipment, such as film badges, pocket chambers, pocket dosimeters, or film rings, and shall require the use of such equipment by each employee who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the applicable occupational limit.
Under OSHA's Ionizing Radiation standard (29 CFR 1910.1096), employers must:
- Ensure that occupational dose limits are not exceeded (1910.1096(b) and (c)).
- Survey radiation hazards in order to comply with the standard (1910.1096(d)(1)).
- Supply appropriate personal monitoring (e.g., dosimeters) (1910.1096(d)(2)).
- Post caution signs, labels, and signals (1910.1096(e)).
- Provide instruction to personnel and post-operating procedures (1910.1096(i)).
Do you have written policies and procedures that demonstrate how you comply with the OSHA Ionizing Radiation Standard?
Have you checked to see if your state has more stringent requirements for Ionizing Radiation and do your policies and procedures comply with the requirements of your state? There are 28 approved OSHA state plans including:
Alaska | https://www.osha.gov/stateplans/ak
Arizona | https://www.osha.gov/stateplans/az
California | https://www.osha.gov/stateplans/ca
Connecticut | https://www.osha.gov/stateplans/ct
Hawaii | https://www.osha.gov/stateplans/hi
Illinois | https://www.osha.gov/stateplans/il
Indiana | https://www.osha.gov/stateplans/in
Iowa | https://www.osha.gov/stateplans/ia
Kentucky | https://www.osha.gov/stateplans/ky
Maine | https://www.osha.gov/stateplans/me
Maryland | https://www.osha.gov/stateplans/md
Michigan | https://www.osha.gov/stateplans/mi
Minnesota | https://www.osha.gov/stateplans/mn
Nevada | https://www.osha.gov/stateplans/nv
New Jersey | https://www.osha.gov/stateplans/nj
New Mexico | https://www.osha.gov/stateplans/nm
New York | https://www.osha.gov/stateplans/ny
North Carolina | https://www.osha.gov/stateplans/nc
Oregon | https://www.osha.gov/stateplans/or
Puerto Rico | https://www.osha.gov/stateplans/pr
South Carolina | https://www.osha.gov/stateplans/sc
Tennessee | https://www.osha.gov/stateplans/tn
US Virgin Islands | https://www.osha.gov/stateplans/vi
Utah | https://www.osha.gov/stateplans/ut
Vermont | https://www.osha.gov/stateplans/vt
Virginia | https://www.osha.gov/stateplans/va
Washington | https://www.osha.gov/stateplans/wa
Wyoming | https://www.osha.gov/stateplans/wy
Now is a good time to review your policy on Ionizing Radiaton or if you do not have one, now is a good time to create one.
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