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ROUTINE TESTING AND MAINTENANCE OF X-RAY EQUIPMENT DURING THE COVID-19 PANDEMIC

At BF Mulholland, we appreciate that employers have many compliance issues to deal with during their working life let alone during the current pandemic, so this letter is to bring you up to date with the current advice about x-ray equipment testing during this difficult time.

UK radiation protection legislation[1], together with associated guidance, applies when using equipment that generates x-radiation and the legislation is enforced by the relevant regulators.  At the time of posting this information, and during our interactions with these regulators, no indication has been given that compliance is to be ‘relaxed’ with respect to x-ray equipment testing.  You should, therefore, continue to address this issue in order to comply with the legislation and any associated guidance.

Recently issued guidance from the Institute of Physics and Engineering in Medicine (IPEM) states, “Practice must be guided by local risk assessment and advice from your medical physics expert. You must prioritise essential and high dose equipment and consider its age and historical performance. Employers must ensure access to equipment for essential testing and maintenance while complying with local infection control policies. When purchasing new equipment, you should still perform essential commissioning and protocol set up [2].

You should, therefore, seek advice from your appointed Radiation Protection Adviser (RPA)/Medical Physics Expert (MPE).  Our guidance, as a general principle, is that you should:

  • Check the date of the last time each installed x-ray set was subject to ‘adequate’ testing, i.e. a routine radiological survey or acceptance test; this information should be available on the latest report you received from DD, or any other testing provider that you have used. Testing should be carried out at least every three years for (non-hand-held) intra-oral, panoramic and cephalometric x-ray equipment, and at least annually for hand-held intra-oral and cone beam CT equipment
  • Check the date of the last time each installed x-ray was subject to appropriate maintenance, i.e. an electro-mechanical check (EMC). Maintenance and EMCs should be in accordance with the advice of the manufacturer, the supplier and your appointed RPA.

If you establish that the x-ray equipment is due a routine radiological survey and/or an EMC, you should make arrangements for the equipment to be appropriately tested are made as soon as practicable. The testing may be arranged through BF Mulholland by calling +44 (0) 28 94 452 668; or through your usual provider of x-ray equipment testing.

If you, as the employer, or your employer take the decision to postpone both or either of the tests described above, we suggest that the reason and justification for this decision be documented in the practice’s radiation protection safety management documentation, or your employer, may need to be prepared to defend the decision during any future inspection.

[1] The Ionising Radiations Regulations 2017 / the Ionising Radiations Regulations (Northern Ireland) 2017 [IRR] and the Ionising Radiation (Medical Exposure) Regulations 2017 / the Ionising Radiation (Medical Exposure) Regulations (Northern Ireland) 2018 [IRMER].
[2] https://www.cqc.org.uk/sites/default/files/20200401_Covid-19_IRMER_national_response_updatedv2.pdf
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