[Intl_DxMedPhys] For Ohio physicists

Fri Jan 24 16:04:07 EST 2025

I can give an overview of the process that went into this regulation change. It’s all based off memory from months ago. So, take it for what it’s worth.

A few years ago, regulations were altered to allow basically this same thing for mini c-arms. From the previous regulations:
“(E) Handlers of c-arm fluoroscopic equipment having a maximum SID less than forty-five centimeters
shall not be required to comply with the requirements of paragraphs (A) (5)(e), (A)(5)(f), (A)(10), (A)
(11), and (A)(12) of this rule and paragraph (H) of rule 3701:1-66-02 of the Administrative Code. In
addition, if a radiation expert has specified in the registrant's quality assurance program that an
individual is unlikely to receive a total effective dose equivalent of greater than two millirem in any one
hour or one hundred millirem in a year, the handler shall not be required to comply with the
requirements of paragraph (B)(1) of this rule.”

I was not at the meetings that led to that change. However, it seems to be based off the fact that mini c-arms are unlikely to expose individuals to radiation levels above those which have been considered safe to the public.

When these rules came up for periodic review again, there was an individual who was vocal that all this should be expanded with all regulations being dose based. There is some sound logic there that if it’s a safe dose to the unprotected public, radiation workers shouldn’t have to protect themselves either. There were several physicists in attendance, and there was much discussion on the topic which I believe had been brought up several times in the past.

When the dust settled, the wording for mini c-arms was expanded to include all fluoroscopy. I, like others who have chimed in, have given recommendations that the change be ignored. I believe the reason that the regulation was changed was that it put the power into the hands of the radiation experts to determine what was appropriate. The downside being that it’s very difficult (nearly impossible?) to enforce with different individuals meeting different thresholds. You would need to have a radiation survey that shows dose levels to be able to exempt cohorts from wearing lead. This would likely lead to others either griping about being required to wear lead or just not wearing lead.

Hopefully, it’s a little used regulation. I could see some utility if there is a facility where nobody gets over public dose, but I will surely be avoiding it.

Joshua Johnson, MS, DABR
 [cid:image001.jpg at 01DB6E77.16101D40]
1681 W. Old Henderson Road
Columbus, OH 43220
888-245-6672, Ext. 13 (phone)
888-245-6511 (fax)
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From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces at lists.osu.edu> On Behalf Of Nicole Ranger via Intl_dxmedphys_wd_osu_list
Sent: Friday, January 24, 2025 3:18 PM
To: Bob Kobistek <bob at rjkmedphys.com>
Cc: intl_dxmedphys_wd_osu_list at lists.osu.edu
Subject: Re: [Intl_DxMedPhys] For Ohio physicists

Thanks for that context Bob. Let us know if there are factors that influenced the decision that would help provide context. Nicole Sent from my iPhone On Jan 24, 2025, at 2: 10 PM, Bob Kobistek <bob@ rjkmedphys. com> wrote:  Apparently so. 
Thanks for that context Bob.  Let us know if there are factors that influenced the decision that would help provide context.

Nicole

Sent from my iPhone

On Jan 24, 2025, at 2:10 PM, Bob Kobistek <bob at rjkmedphys.com<mailto:bob at rjkmedphys.com>> wrote:

Apparently so. One physicist who attended the meetings contacted me off-list and invited me to contact him directly so he could explain the thought processes that went into that decision. I haven’t done that yet.

I shared this with my radiology directors and am recommending that they do not share this information with the OR management. For the five hospitals where I’m IRRP (IRRP is Ohio-speak for RSO of radiation generating equipment), I have the authority to flat out refuse to accept this option, and that’s what I’m doing.

Robert J. Kobistek, MS, FACR, DABR, MRSE(MRSC™)
Medical Physicist
RJK Medical Physics, Inc.
440-463-7879

PLEASE NOTE MY NEW EMAIL ADDRESS Bob at RJKMedPhys.com<mailto:Bob at RJKMedPhys.com>

From: Nicole Ranger <nicoletranger at yahoo.com<mailto:nicoletranger at yahoo.com>>
Sent: Friday, January 24, 2025 3:00 PM
To: Wunderle, Kevin <Kevin.Wunderle at osumc.edu<mailto:Kevin.Wunderle at osumc.edu>>
Cc: Bob Kobistek <bob at rjkmedphys.com<mailto:bob at rjkmedphys.com>>; intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>
Subject: Re: [Intl_DxMedPhys] For Ohio physicists

On the whole I think this is a bad idea.  Principally because those who are aware of this loophole will pressure their MPs or RSOs to implement this even if the MP or RSO is concerned about compliance and managing adherence to the recommended limits.  Did the MPs on the state advisory board participate in discussions prior to this rule change?

Nicole

Sent from my iPhone

On Jan 24, 2025, at 10:49 AM, Wunderle, Kevin via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>> wrote:

Hi Bob,

I echo your concerns and sentiment. Additionally, as you know, the ODH claims that it is the operator of a fluoroscope who is responsible for the safety of the persons present (and exposed) during fluoroscopic imaging. How are they supposed to know who does or doesn't require lead protection? And, if those individuals have occupational dosimetry, they will clearly need to have different dosimeter processing without EDE correction since they won’t be wearing lead apparel (unlikely site will pay attention to that and leave it on).

If there is any silver lining it is that a radiation expert must provide the documentation and parameters for implementing this allowance, and we should have the right to not provide such evidence and state that it is not acceptable in our professional judgement. I realize on the consulting side it may be trickier to take that stance. Even if provided though, the site will have to have administrative controls in place to monitor compliance (also not going to happen) otherwise jeopardize their compliance.

All the best,
Kevin

<image001.png>

Kevin Wunderle, PhD, FAAPM, FACR
Professor, Department of Radiology
Diagnostic Medical Physicist
395 W. 12th Avenue,
Floor 4, Room 424
Columbus, OH, 43210
216-245-5513 Mobile
kevin.wunderle at osumc.edu<mailto:kevin.wunderle at osumc.edu>

From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+kevin.wunderle=osumc.edu at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list-bounces+kevin.wunderle=osumc.edu at lists.osu.edu>> On Behalf Of Bob Kobistek via Intl_dxmedphys_wd_osu_list
Sent: Friday, January 24, 2025 10:29 AM
To: intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>
Subject: [Intl_DxMedPhys] For Ohio physicists

Sorry for clogging up an international list for an Ohio-specific question, but others may have input as well. New ODH regulations that went into effect last month now allow personnel participating in fluoroscopic procedures to be present in
Sorry for clogging up an international list for an Ohio-specific question, but others may have input as well.

New ODH regulations that went into effect last month now allow personnel participating in fluoroscopic procedures to be present in the procedure room without a protective apron if the physicist provides time and distance limitations. In other words, I can do calculations and allow certain members of OR staff to be in surgery cases as long as they stay at least X meters away from the table for no more than Y minutes of fluoro per week. Here’s the new reg:

“Any individual who is in the room during the fluoroscopic procedure will be adequately protected by standing behind a whole body protective barrier or will wear a protective lead apron of not less than 0.25 millimeter lead equivalent. If a handler's radiation expert includes documented evidence and specifies in the quality assurance program a distance and time interval in the room from the source at which an individual is unlikely to receive a total effective dose equivalent of greater than two millirem in any one hour or one hundred millirem in a year, the handler can forgo the use of a protective barrier or lead apron for that time at that distance.”

My first comment is, “Are they serious?!!??” I see this as a nearly impossible option given that the responsibility will ultimately fall on us to show that we track the movements and exposure of these individuals exempted from wearing lead aprons. Also, the time / distance limitations are moving targets. Someone can be 3 meters from table for a longer time than 2 meters. And how is the unshielded person supposed to keep track of fluoro time?

Even if there are personnel that we can exempt from wearing aprons because they pop in and out of OR’s for short periods, I can see, down the road, inspectors looking for some sort of tracking to verify that they are not overstaying their allowed exposure time.

Are any Ohio physicists planning to take advantage of this new regulation? And if so, how are you addressing the issues I mentioned?

Robert J. Kobistek, MS, FACR, DABR, MRSE(MRSC™)
Medical Physicist
RJK Medical Physics, Inc.
440-463-7879

PLEASE NOTE MY NEW EMAIL ADDRESS Bob at RJKMedPhys.com<mailto:Bob at RJKMedPhys.com>

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