X-Ray Equipment
3.0 X-Ray Equipment
The following rules set the requirements for the safe use of diagnostic, analytical, cabinet or miscellaneous X-ray systems at Virginia Tech. These rules are in conformity with the radiation safety standards promulgated by the Commonwealth of Virginia.
3.1 Classification of Users
- Laboratory Authority - A laboratory authority may independently purchase, possess, and use X-ray producing equipment; directly responsible for the equipment and the users on the authorization.
- Principal User - A principal user works under the indirect supervision of an authorized user, may supervise users and request amendments.
- User or Operator - An operator uses X-ray equipment under the indirect supervision of a laboratory authority or principal user. A user cannot request amendments and has no supervisory power.
- Holder - A holder is authorized only to hold patients, cassettes, or animals during an X-ray exposure.
3.1.1 Responsibility of Laboratory Authority
The Laboratory Authority is responsible for the safe operation of the X-ray equipment under his control and to ensure that:
- Users are adequately instructed in safe operating procedures and are skilled in the safe use of the equipment.
- Users have received training in radiation safety as considered necessary by the Radiation Safety Committee.
- Written safety rules and procedures are provided to all users of the equipment, including any restrictions of the operating techniques required for the safe operation of the system.
- All X-ray equipment under his control is registered with the Radiation Safety Office.
- The equipment, facility and the use of the equipment meet the applicable Federal, State and local regulations.
- Users wear the appropriate personnel monitoring devices.
- The Radiation Safety Office is notified of any changes in the equipment, facility, or personnel using the equipment.
3.1.2 Responsibilities of Workers
Those who work with X-ray producing equipment, both staff members and students, have the following responsibilities:
- Follow safe operating procedures for the use of the equipment.
- Observe the rules presented in this manual for the safe use of ionizing radiation.
- Immediately notify the Authorized User or the Radiation Safety Office of any defects or deficiencies in radiation protection devices and procedures.
- Maintain radiation doses at a level that is as low as reasonably achievable (ALARA).
3.2 Obtaining an Authorization
An individual wishing to become a Laboratory Authority shall submit the form "Authorization to Use X-ray Producing Equipment" ( doc | pdf ) to the Radiation Safety Office. A Laboratory Authority is permitted to possess X-ray producing equipment.
The application will be submitted to the Radiation Safety Committee for review. The applicant will receive a copy of the application signed by the chairman and the Radiation Safety Officer.
3.3 Radiation Safety Training
All individuals who wish to independently operate diagnostic, analytical, or cabinet X-ray systems, or who will be used as holders, shall receive instruction in and demonstrate ability in:
- General properties of ionizing radiation
- Principles of radiation detection
- Radiation hazards associated with the use of the equipment
- Biological effects of ionizing radiation
- Procedures to minimize exposure
- Virginia Tech radiation safety requirements
- Emergency procedures
Ability shall be demonstrated by passing a written examination administered by the Radiation Safety Office.
Individuals who will operate miscellaneous equipment, e.g. electron microscopes, are not required to complete documented radiation safety training. However, all individuals should receive hands-on instruction and training before independently using a miscellaneous system.
Other exceptions to radiation safety training will not be granted because of previous training, experience, or education.
3.3.1 Procedure
All X-Ray radiation safety training is available on-line. To access the training go to the following web address: https://www.ehss.vt.edu/programs/RAD_blackboard.php
The successful completion of the radiation safety training does not automatically authorize you to use x-ray equipment. You must be added to an approved local authorization by an amendment submitted by a principal user of a laboratory, or in the case of new faculty members, by the submission of an application to use x-ray producing equipment.
3.4. X-ray Use in Classroom Instruction
Only a Laboratory Authority can purchase X-ray equipment.
All orders for X-ray producing equipment are to be processed according to current University procedures, as defined by the Radiation Safety Committee.
The purchaser must consult with the Radiation Safety Office concerning the adequacy of the facility where the equipment will be used.
Donated equipment must be pre-approved by the Radiation Safety Officer prior to the equipment's arrival on-site.
The purchaser is to notify the Radiation Safety Office on receipt of the equipment and provide the information necessary to register the unit with the Commonwealth of Virginia.
Radiation Safety personnel will conduct a leakage and area survey during the initial operation of the equipment.
3.5 Obtaining and Disposing of X-ray Equipment
All x-ray equipment purchases must be approved by the Radiation Safety Officer. Authorization, location of instruments, and protocols must be considered before purchase. Any x-ray equipment no longer being used, must be disposed of through the Surplus Property program. Contact the RSO for approval to dispose x-ray equipment and to ensure that the State is informed of disposal.
3.6 Request by Workers For Inspections
Any worker who believes there is a violation of the rules and regulations presented in this manual may request an inspection of that facility by notifying the Radiation Safety Officer. The worker's name will be kept anonymous. During inspections the safety officer may confer privately with workers. Workers may bring to the attention of the safety officer any past or present condition they believe may have contributed to or caused a violation. No licensee shall dismiss or in any manner discriminate against a worker because a complaint was filed with the Radiation Safety Office.
3.7 Disciplinary Procedures
Any program that requires compliance with regulations must have a means for disciplinary actions. The following section describes the disciplinary actions applicable to the use of radioactive material.
3.7.1 Definition of Violations
Violations of the rules and regulations in this manual will be classified as follows:
- Class I - Administrative or procedural deficiency of a relatively minor nature, e.g., failure to maintain survey records properly, failure to wear a required personnel monitoring device.
- Class II - Major violations that could result in excessive radiation exposures to personnel, or willful and repeated negligence, e.g., loss of radioactive material due to negligence; improper use of ionizing radiation, materials or devices in such a way as to lead to potential injury or liability.
3.7.2 Penalties
- Class I - If three citations are issued within a 1-year period, operations under an Authorization will automatically be suspended, pending
a review by the Radiation Safety Disciplinary Subcommittee.
- Notice of Concern
A Notice of Concern (NOC), issued by the Radiation Safety Officer, will explain the nature of the violation and the potential for incurring further disciplinary actions. At the discretion of the Radiation Safety Officer, the NOC can be issued as a warning or as the first citation. A copy of the NOC will be kept on file. - First Violation
The Chairman of the Radiation Safety Committee will issue a letter of reprimand with a copy to the department head. - Second Violation
An immediate cessation of operation under an Authorization will be required, normally in effect for two weeks. This action may be changed, pending a review by the Radiation Safety Disciplinary Subcommittee. The Chairman of the Committee will issue a letter of reprimand with copies going to the department head and dean of the college involved. - Third Violation
An immediate cessation of operation under an Authorization will be required, pending review of the incident by the Radiation Safety Disciplinary Subcommittee. The Chairman of the Committee will send a suspension letter with copies going to the department head, dean of the college involved and the Vice-Provost for Research. After a period of one year, the Committee will review reinstatement of the Authorization.
- Notice of Concern
- Class II - For a Class II violation, an immediate cessation of operation under an Authorization will be required, pending review of the incident by the Radiation Safety Disciplinary Subcommittee. The Chairman of the Committee will send a suspension letter with copies going to the department head, dean of the college involved and the Vice-Provost for Research.
3.7.3 Determination of Responsible Person
Citations will normally be issued to the Authorized User. However, in situations beyond the Laboratory Authority's control, such as willful negligence by an individual, citations will be issued to the specific person responsible. The Disciplinary Subcommittee can make this determination, where questionable.
3.7.4 Determination of The Class of Violation
A preliminary determination of the class of violation will be made at an interim meeting of the appropriate Radiation Safety Officer and the Chairman of the Radiation Safety Committee. A review of Class I first violations will take place at the next regularly scheduled meeting of the Radiation Safety Committee. A meeting of a Disciplinary Subcommittee will be convened by the chairman as soon as practicable for Class I second and third violations and for Class II violations. The individual cited will be invited to appear before the subcommittee to assist in the determination of these classes of citations.
3.7.5 Disciplinary Actions
The Disciplinary Subcommittee will determine the appropriate action to take for all Class I violations for second and third offenses and for Class II violations. The Disciplinary Subcommittee is empowered to impose the disciplinary actions decided upon. However, the Radiation Safety Committee will review the decisions of the Subcommittee at the next regularly scheduled meeting or the chairman will call a meeting as soon as practicable upon an appeal by the individual cited. The Radiation Safety Committee may approve or modify the actions of the Disciplinary Subcommittee as the final authority on radiation safety matters at the University.
The results of any disciplinary actions taken by the Radiation Safety Disciplinary Subcommittee, after their consideration of the incident, and of any appeals made to the Radiation Safety Committee will be sent to the same individuals to whom the original materials were sent.
3.7.6 Appeals
An individual has the right to appeal any action of the Disciplinary Subcommittee to the Radiation Safety Committee. The Chairman will call a meeting as soon as practicable.
3.8 Variances
An authorized user may apply to the Radiation Safety Committee for an exemption from the requirements of these regulations.
The request must include the reason the variance is being sought, and alternative methods that will be used to ensure that the health and safety of personnel and the environment will not be compromised.
The application for a variance is to be sent to the Radiation Safety Office or the chairman of the Radiation Safety Committee. The request will normally be acted on at the next scheduled meeting of the committee.
A special meeting may be called by the Chairman if it is believed necessary. The Authorized User may be present at the meeting to discuss his request for the variance.