Re: Multi-clinic Monitoring

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

First, it depends on the State regulations.  However, in Texas (and
probably most states), each clinic is responsible for ensuring Dr. X
does not exceed his total occupational limit.  As such, each clinic
must ensure Dr. X provides complete copies of his records.

In other words, the clinic is the registered (regulated) party, not
the physician.

Wes

> Date:          Thu, 4 Apr 96 12:19:11 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          FranzJosef@aol.com
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Multi-clinic Monitoring

> We have a fair number of cases where Radiologist X practices at Clinic A, B
> and C. Each clinic is a separate entity with respect to x-ray machine
> registrations so each clinic furnishes the radiologist with a separate
> personnel monitor (in our case serviced by three separate companies).
>
> It is known that a registrant must insure that the radiologist not exceed the
> allowable MPD dose equivalent from the use of registered machines at the
> registrant's clinic.
>
> This implies that it is possible for multi-clinic practicing Radiologist X to
> receive a total dose equivalent that exceeds the MPD-theoretically a
> cumulative dose Equivlent (DE) that is 3 times the allowable MPD.
>
> 1. Is a clinic responsible for gathering monitoring data from other clinics
> so that a global DE for Radiologist X is monitored by the clinic?
>
> 2. If the clinic is responsible for the monitoring of the cum. DE and
> Radiologist X's cumulative dose equivalent exceeds the maximum single MPD
> (5000 mrem) must all clinics refuse to allow Dr X from practicing even though
> the Dr's dose equivalent at each clinic is below the MPD?
>
> 3. Is Radiologist X soley responsible for keeping track of her cumulative
> dose equivalents received at all clinics? This implies that each clinic need
> only be concerned with the accumulated DE at their clinic.
>
> I would greatly appreciate any comments and assistance in clearing up this
> dilema.
>
> Franz St. George, Ph.D.
> Medical Physicist
>
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Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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