The X-ray Program registers approximately 19,000 radiation-producing machines (such as x-ray machines); sets performance criteria for them; and authorizes non-department qualified private inspectors to perform the evaluations and non-department service companies to install and repair the machines.
Machines must be inspected within the established frequency of either 1,3, or 5 years based on the type of use. Any X-ray machine that is determined to be unsafe for use is restricted from use until the X-ray machine is repaired by a service company, and re-inspected by a Qualified Private Inspector, or permanently removed from service. These regional radiological health specialists audit and monitor private sector inspections and perform compliance inspections of X-ray facilities. The remainder of this page will discuss the Private Inspectors. Topics discussed follows:
- Purpose
- Qualifications
- Application
- Private Inspectors List
- Inspection Forms
- Submittal of inspection reports
- Enforcement
- Accreditation Boards
- Professional Societies
Purpose
Private Inspectors conduct X-ray machine safety inspections to ensure the use of X-ray producing machines and the facility’s operational procedures conform with the Virginia Department of Health’s (VDH) regulations. The information contained in the inspection reports that the Private Inspectors provide VDH is used to determine whether a machine is certified for use in the healing arts. There are over 19,000 X-ray machines registered with VDH and each machine used in the healing arts must be periodically inspected. VDH has a limited number of inspectors available to conduct X-ray machine inspections. Much of a VDH inspector’s time is spent following up on reported non-compliances, performing special inspections for the U.S. Food and Drug Administration and conducting enforcement actions. Private Inspectors provide a valuable service to ensure that X-ray machine owners can meet their obligation to have their X-ray machines inspected and certified for use.
Many private inspectors are also medical physicists who provide specialized services to meet other regulatory requirements or support clinical services. These services may include medical physics support for mammography facilities, nuclear medicine departments, radiation therapy treatment planning and shielding design. Qualifications to provide these services may require distinctively different credentials and are separate from those of a Private Inspector.
Private Inspectors providing physics support to a mammography facility need to take special care in documenting their credentials.
Qualifications
Individuals interested in becoming a Private Inspector must meet the criteria established in the regulations 12VAC 5-481-340. Please read the following regarding an exemption to the non-medical private inspector application.
Non-Medical Private Inspector Exemption
Application
For new applicants, the application may be downloaded: RH-F-27
Along with the application, the following are required:
- copies of board certifications
- copies of diploma in one of the physical sciences or engineering
- original transcript sent directly from university to VDH
- a signed letter by a mentor that provides documentation of work experience with at least one year of applicable X-ray inspection experience.
The applicant will be asked if they are available for providing consultation or inspection services to X-ray machine registrants in Virginia. If this is the case, the applicants name will be placed on our published Private Inspectors list once the credentials have been verified. The Private Inspector’s list is made available to the public.
Some employers restrict their medical physicists from performing work outside of their primary work place. Applicants in this situation will have their name placed on the master list of Private Inspectors; however, this list is not generally distributed. Employers may contact VDH to confirm an individual’s status as a Private Inspector.
VDH staff will carefully review each application and verify the information provided. This will also include a verification of certifications and degrees obtained.
**Currently registered Private Inspectors, please use our update sheet for renewals: Update Sheet
Fees
Initial application fee of $150.00 will be billed once the application is approved and processed.
Annual registration fee of $150.00 in order to remain on the published and/or unpublished list.
Private Inspector’s List
The Private Inspector List is periodically updated. Private Inspectors should inform VDH whenever any of their information changes. For a copy of the list, click on this link: Qualified Private Inspectors.
Inspection Forms
Private Inspectors may contact VDH for the multi-part inspection forms used to report inspection data or may down load the forms. Private inspectors will need access to specialized equipment for conducting the appropriate measurements required for a given X-ray machine, such as: calibrated ion chamber, light meter and X-ray film.
General Administration Items Form –RH-F-21 (01/2020)
General Radiographic Systems RH-F-22 (01/2020)
Fluoroscopic Radiographic Systems RH-F-24 (01/2020)
Computed Tomography (CT) Machines RH-F-28 (01/2020)
Dental Intra-oral Radiographic RH-F-23 (01/2020)
Dental Panographic RH-F-26 (01/2020)
Veterinary Radiographic RH-F-25 (01/2020)
Podiatric Radiographic RH-F-25 (01/2020)
Bone Density Radiographic RH-F-25 (01/2020)
Radiation Therapy Machines RH-F-29 (01/2020)
Analytical/Industrial RH-F-3 (01/2020)
Other helpful forms
The following should be posted for each inspection:
- A copy of the Notice to Employees RH-F-12 (01/2020)
- A copy of the Safety Procedures (as applicable):
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- Radiation Safety Procedures RH-F-41 (01/2020) — for Dental Offices
- Radiation Safety Procedures RH-F-42 (01/2020) — for Veterinary Offices
- Radiation Safety Procedures RH-F-43 (01/2020)–for Non-Medical Offices
- Radiation Safety Procedures RH-F-40 (01/2020) — for All others
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- A copy of the Operator’s List RH-F-31 (01/2020)
- The green or yellow certificate for each x-ray unit
Submittal of Inspection Forms
The Private Inspector is required to provide the facility a copy of the inspection report within 14 days of the completion of the inspection (12VAC5-481-1591-D). The X-ray machine owner or whoever has administrative control of the machine is required to provide a copy of the inspection report to VDH. The Private Inspector may provide a copy of the inspection report directly to VDH as a service to their client. The Private Inspector should let their client know if this is the case. It would be helpful for the Private Inspector take the time to discuss with the facility’s representative the inspection report and any findings of non-compliance and how they may be corrected.
Enforcement
In the last decade two of the listed Private Inspectors were found to have submitted fradulent degrees. Unfortunately for them, the inspection services provided were also regulated by the U.S. Food and Drug Administration. Each was prosecuted under federal law and sentenced to a prison term of five years. Since then VDH staff have taken considerable steps to ensure verification of credentials of existing Private Inspectors and new applicants.
VDH inspectors may also follow up on a Private Inspector’s inspection to ensure the quality of the inspection.
Accreditation Boards
American Board of Radiology http://theabr.org/
American Academy of Health Physics/American Board of Health Physics http://www.hps1.org/aahp/
Professional Societies
American Association of Physicists in Medicine http://www.aapm.org/
Health Physics Society http://www.hps.org/
Office of Radiological Health | 109 Governor Street, 7th Floor | Richmond, VA 23219
Telephone (804) 864-8150 | X-ray Fax: (804) 864-8175