EPA 520/4-76-002
         BACKGROUND REPORT
RECOMMENDATIONS ON GUIDANCE

                FOR

   DIAGNOSTIC X-RAY  STUDIES
  FEDERAL HEALTH CARE FACILITIES
 i   ENVIRONMENTAL PROTECTION AGENCY
;/'  INTERAGENCY WORKING GROUP ON MEDICAL RADIATION
      SUBCOMMITTEE ON PRESCRIPTION OF EXPOSURE TO X RAYS

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                                               EPA  520/4-76-002
 RECOMMENDATIONS ON GUIDANCE FOR DIAGNOSTIC X-RAY
     STUDIES IN FEDERAL HEALTH CARE FACILITIES
                     Report of

Subcommittee on Prescription of Exposure to X rays

  Interagency Working Group on Medical Radiation
       U.S. Environmental Protection Agency
              Washington, D.C. 20460
                    March 1976

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                                PREFACE
     The Administrator of the Environmental Protection Agency formed an
Interagency Working Group on July 5, 1974, to develop guidance to
reduce unnecessary radiation exposures from the use of x rays in the
healing arts in Federal health care facilities.  The consensus of this
group was that it is desirable and possible in Federal facilities to
reduce exposure from diagnostic uses of x rays by: 1) eliminating
clinically unproductive examinations, 2) assuring the use of optimal
techniques when examinations are performed, and 3) requiring
appropriate equipment to be used.  As a result of this consensus a
Subcommittee on Prescription of Exposure to X rays (SPEX) was
established to examine factors to eliminate clinically unproductive
examinations and consider the feasibility of reducing radiation
exposure in productive studies.  Another Subcommittee on Techniques of
Exposure Prevention was formed to examine the second and to some extent
the third subject areas.  The third area is being regulated by the U.S.
Food and Drug Administration which has recently issued x-ray equipment
performance standards.

     The mission of SPEX was to examine diagnostic radiology procedures
and develop recommendations which have immediate applicability in
Federal facilities.  The members of SPEX were especially mindful that
their recommendations should not preclude necessary uses of x rays in
diagnostic medicine.  Serious efforts were made, however, to formulate
recommendations that would eliminate the prescription of unwarranted
examinations and eliminate the taking of unproductive radiographs.
This approach has recognized the need for expert diagnosticians,
principally radiologists, to be involved in medical decisions involving
the prescription of diagnostic x-ray examinations.

     The SPEX recommendations basically result from two considerations:
1) the clinical decision to order a particular examination, and 2) the
optimization of the number of radiographic views required in an
examination.  Fortunately, a reduction in unproductive radiation
exposure to the patient and the goals of good diagnostic radiology are
directly related in that elimination of unproductive diagnostic
examinations achieves both.  We believe the recommendations represent
consensus judgment of appropriate prescription of x-ray  examinations in
Federal health care facilities.  It should be recognized that the body
of knowledge on both the radiation exposure and efficacy of x-ray
examinations is rapidly changing and the recommendations will, of
necessity, need periodic review and appropriate revision.
                                Charles  W. Ochs, MC, USN
                                Chairman, Subcommittee on
                                Prescription of Exposure to X rays

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                                MEMBERS
Department of the Navy
Captain Charles W. Ochs, MC, USN, CHAIRMAN
Captain James Dowling, MSC, USN*
Captain William Bottomley, DC, USN
Commander James Spahn, MSC, USN
Commander Peter Kirchner, MC, USN

Veterans Administration
Leonard Bisaccia, M.D., VICE CHAIRMAN
Donald Knoeppel,  D.D.S.
James Smith, M.D.

Department of the Army
Lt. Col. Robert Quillin, MSC, USA

Department of the Air Force
Colonel John Campbell, MC, USAF
Colonel Charles Mahon, MC, USAF

Environmental Protection Agency
James E. Martin,  Ph.D.
DeVaughn R. Nelson,  Ph.D.
Harry Pettengill, Ph.D.

Consultants
     Otha Linton, M.S.J.
     Director of  Governmental Relations
     American College of  Radiology

     S. David Rockoff, M.D.
     Chairman, Department of Radiology
     George Washington University Medical center

     William S, Cole,- M.D.
     Associate Director - Bureau of  Radiological Health
     U.S. Food and  Drug Administration

     John Doppman,  M.D.
     Chief of Radiology
     National Institutes  of Health
 *Deceased
                                    111

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                               CONTENTS

                                                                      Page
PREFACE                                                                 n

MEMBERS                                                                lii

INTRODUCTION AND RECOMMENDATIONS                                        i

BACKGROUND                                                              7

     Administrative Control or Convenience

     Criticism and Legal

     Intellectual Curiosity

     Inexperi ence

     Public Health Screening

PRESCRIPTION CONSIDERATIONS                                             1C

     Qualifications to Prescribe X rays

     Screening and Administrative Programs

     Mammography

     Dental Radiography

     Self-referral Examinations

PROCEDURAL CONSIDERATIONS                                               21

     General Considerations and Review Plans

     Minimum Number of Examinations  and Views

     Patient History  and Physical Condition

EQUIPMENT CONSIDERATIONS                                                25

     Equipment Use Policy

     General Radiographic  Equipment  Policy

     Fluoroscopic Equipment Policy

REFERENCES                                                              32

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                   INTRODUCTION AND RECOMMENDATIONS








     One of the most significant aspects of good medical care is the



use of x rays to diagnose and define the extent of disease or physical




injury.  The per capita use of x rays in medicine and dentistry has




expanded rapidly in the United States due to wider availability of




services, new equipment, and an increase in sophisticated diagnostic




examinations.  Although many procedures now produce less exposure per




film, the increased number of procedures has increased the radiation




exposure to the population.  A number of medical and scientific groups




generally agree that there is unproductive radiation exposure from x-




ray uses that could, and should, be reduced and research efforts are in




progress by several organizations such as the American College of




Radiology to determine the efficacy of certain radiographic




examinations.




     The most important factor in reducing radiation exposure is to




eliminate clinically unproductive procedures.  The factors involved in




accomplishing this goal were examined by the Subcommittee on




Prescription of Exposure to X rays which was made up of physicians,




dentists, and physicists from the three military services, the Veterans




Administration, and the Environmental Protection Agency.  The




Subcommittee had consultants from George Washington University, the




Public Health Service, the Food and Drug Administration, and the




American College of Radiology  (see list on page iii) .

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                                   2




     Appropriate prescription of x-ray examinations involves two major




categories:  the clinical decision to order a given examination, and the




choice of the number and type of views required to conduct it within




the principles of good radiological practice.  Establishment of routine




examinations either for administrative non-medical reasons or




efficiency of clinic operation tends to be counterproductive to




minimizing exposure.  In the first category the qualifications and




demonstrated proficiency of those who order diagnostic procedures




largely determine whether the procedure will be productive.  The same




factors are also important in the second category with equipment,



technician training, and administration of x-ray examinations also




playing important roles.  Within this framework, the Subcommittee has




made the following recommendations for guidance in the prescription of




diagnostic x-ray examinations in fixed Federal and contractor




installations:




     1.  Privileges to request general radiographic or fluoroscopic




examinations should be limited to Doctors of Medicine or Osteopathy who




are eligible for licensure in the United States or one of its




territories or commonwealths; exception should only be granted for




properly trained physician-supervised individuals such as physician




assistants, nurse practitioners, and persons in post-graduate training



status or for life-threatening situations.




     2.  Privileges to request dental x-ray examinations should be




limited to Doctors of Dental Surgery or Dental Medicine who are

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eligible for licensure in the United States or one of its territories



or commonwealths; exception should he granted only for persons in post



graduate training status under the supervision of a person meeting such



requirements.




     3.  Privileges to request specialized radiographic or fluoroscopic



examinations such as angiography, pneumoencephalography, tomography, or



other complex studies requiring many exposures should be restricted to



physicians and dentists meeting recommendations of credentialing



committees for prescription of general radiographic procedures and who



have had advanced training in the medical specialty involved in order



to determine the need for and to fully evaluate the results of such



special examinations for definitive medical care.



     4.  Routine chest x-ray examinations should not be performed for



tuberculosis screening, as a Federal requirement for employment, or as



an established part of periodic physical examinations except in



epidemiologically determined high-risk groups; performing such



examinations with photofluorographic equipment is not advised because



of high radiation exposure.  Chest x-ray examinations should generally



not be done  merely for hospital admission on patients under the age of



40, or as part of routine prenatal care, unless a clinical indication



of chest disease exists.



     5.  Mammography examinations should not be used to screen



asymptomatic women under the age of 35; for asymptomatic women between



age 35 and 50 the screening policy should be based on an annual review

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of current data on yield, radiation risks, and economic and social




factors.  Screening of women above age 50 appears justified at this




time.



     6,  Radiographic examinations obtained for the evaluation of




cancer patients should be reviewed for their efficacy both for the




initial evaluation and required followup care.  Existing protocol




studies should be evaluated periodically to establish the appropriate




studies for evaluating the various types of malignancy and its




metastatic spread.




     7.  Dental x-ray examinations should be prescribed only on the




basis of a clinical evaluation by a dentist; neither a full-mouth




series  nor bitewing radiographs should be part of routine preventive




dental  care.  Exceptions may be made for certain groups for forensic



purposes.




     8.  The use  of self-referral x-ray examinations should be limited




to  studies unique and required by the specialty of the physician




performing them and be consistent with a peer review policy.  The




examination should be performed only by physicians qualified to



supervise, perform, and  interpret examinations unique to that



specialty.




     9.  A current document listing the standard views for defined




examinations should be provided for all x-ray equipment operators and




tailored to the department and equipment available.  The number,




sequence, and types of standard views for an examination should be

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                                   5



problem-oriented and kept to a minimum; additional views should only be



authorized by the supervising diagnostician.



     10.  Follow-up x-ray examinations should be done only at time



intervals long enough to make proper decisions concerning continuation



or alteration of treatment.




     11.  Requests for x-ray examinations should be considered as



medical consultations between the clinician and the diagnostician and



should state the diagnostic objective of the examination and detail



relevant medical history including results of previous diagnostic x-ray



examinations.  The radiologic diagnostician should have the authority



to direct the examination to obtain the diagnostic objective through



the addition, substitution, or deletion of prescribed views; this



should be done in consultation with the requesting clinician whenever



practicable.



     12.  Operation of medical and dental x-ray equipment should be



permitted only under  a policy which is established and reviewed



annually by the responsible authority; this policy should specify the



amount of training required for  x-ray equipment operators and whether



authorization to operate x-ray equipment is limited or general.



     13.  Equipment used in Federal and contractor health care



facilities should conform to the Federal Diagnostic X-Ray Equipment



Performance Standard  (21 CFR Subchapter J) as soon as practicable; in



the interim all equipment should conform with parts F. 4, F. 5, F.6, and



F. 7 of the 1974 "Suggested State Regulations for Control of Radiation"

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                                   6




where applicable.  A plan which is reviewed annually should exist for




timely replacement of diagnostic x-ray equipment used by Federal




agencies.



     14.  All fluoroscopy units in Federal and contractor health care




institutions should provide image-intensification; non-radiology




specialists such as orthopedists, neurosurgeons, gastroenterologists,




cardiologists, chest surgeons, etc. who are determined by the




responsible authority to require fluorcscopy, and are qualified to use




it, should be limited to the use of units with electronic image-holding




features when practicable.




     15.  These recommendations, which are intended for fixed health




care facilities in the United States or its territories and




possessions, should be reviewed at timely intervals to accommodate




advances in radiological practices and changing levels of technological




sophistication.

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                              BACKGROUND








     The ideal circumstance in which to order a diagnostic x-ray



examination is for a physician or dentist qualified in his speciality




to have determined that sufficient clinical symptoms or history




necessitate the examination to either establish disease or injury or




its extent.  Many x-ray examinations are prescribed, however,  that do




not necessarily satisfy such clinical-historical prerequisites.  The




major factors involved in ordering unnecessary x-ray examinations



appear to be:




Administrative Control or Convenience




     Once an x-ray facility is established a minimum amount of use may



be required to justify its existence.  A small health care unit may




tend to perform x-ray examinations because of location and "convenience




to the patient" rather than to refer him to a more appropriate




radiology facility.  Patient, facility, and physician "convenience" may




be interrelated and difficult to separate in determining proper medical




care.




Criticism and Legal



     Many x-ray examinations may be ordered principally to preclude




criticism that everything that could be done for the patient was not




done or that the established practice was not followed.  This




consideration probably exists in all medical practice.  In some cases




fear of criticism may be manifested in actions to provide a legal

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                                   8




record that good practice was followed even though the physician's



course of treatment would not be altered by the result.   Unfortunately,




such factors lead to established routines which eventually lead to




usual practice and unnecessary radiation exposure.  Other routine x-ray




examinations may te decreed by local, state, or Federal laws for pre-




employment physicals for various occupations, workmans compensation,




and disability compensation.  These examinations may be of economic




importance to the patient in deciding his compensation,  yet have




minimal value for his medical care.  Certain high risk groups require




survey studies for medical purposes; however, tney should be evaluated




periodically.




Intellectual Curiosity




     Physicians, from time to time, obtain extra radiographic studies




to determine the presence, progress, or exact nature of some entities,




the knowledge of which has little immediate or long-term implication in



the care of the patient.



Inexperience




     Medical students, interns, residents, and some non-physician




practitioners may not have developed medical judgment as to which test




would be most efficacious.  Because of such inexperience, examinations




may not be ordered in the best sequence and may even interfere with the




next test to be done.  Also, practitioners with inadequate training in




radiological techniques and interpretation may supervise both the




taking and interpretation of radiographic examinations.  An extensive

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                                   9



series of examinations is sometimes performed to rule out various



conditions for which there are no clinical indications.



Public Health Screening




     Certain groups may be examined in large numbers by screening



programs for diseases such as tuberculosis, pneumoconiosis, or breast



cancer.  Frequently the decision to take such an examination is made by



the patient without physician consultation.  In an attempt to provide



comprehensive bill-of-health physicals, unnecessary x-ray studies may



be conducted as  a  routine part of the physical examination.



     These five  factors influence the number of x-ray examinations and



add to the radiation exposure received by the population.  In addition



to the number of examinations, the number and type of radiographic



projections used in each examination, whether clinically indicated or



determined for other reasons, also influences the radiation exposure.



These factors, as  well as other aspects of eliminating unproductive x-



ray exposure were  examined by the Subcommittee on Prescription of



Exposure to X rays on the basis of three considerations: Prescription,



Procedure, and Equipment.  The Subcommittee's recommendations were



developed from considerations directed toward health care in Federal



and contractor facilities and their implementation should promote a




reduction in patient exposure.

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                      PRESCRIPTION CONSIDERATIONS








     Clinicians who prescribe an x-ray examination have a dual



responsibility to assure that requisite diagnostic information is




obtained and that the radiation administered is done so only with




commensurate benefit.  The benefits derived from the use of x-ray




examinations in medical diagnosis are very high and account for its




widespread use.  In 1970 the number of radiographic procedures per




capita was estimated to be increasing at rates varying from 1-4% per




annum (1).  Since 1970, the rate is most likely higher due to new and




improved developments in radiological diagnostic modalaties and




procedures such as mammography, angiography, and computerized axial




tomography.  Because of this upward trend in x ray use and the




importance of minimizing the aggregate population exposure, it is quite




important to insure that the prescription of any x-ray examination is




necessary.



Qualifications to Prescribe X rays




     The qualification of medical personnel authorized to prescribe




diagnostic x-ray examinations is the most important factor in limiting




the prescription of unproductive examinations.  Requests for x-ray




examinations in general radiography or fluoroscopy in Federal health




care facilities should be made only by a person possessing a M.D. or




D.O.  degree who is eligible for licensure or licensed where required




by statute.  Properly trained and physician-supervised individuals such
                                  10

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                                   11



as physician assistants, nurse practitioners, and persons in



postgraduate medical training status do not have to meet the above



requirements but they must be under the supervision of one who does.



     Any requests in specialized radiography and fluoroscopy such as



angiography, pneumoencephalography, computerized axial tomography, or



other complex studies requiring many exposures should be made by a



person who meets the above requirements, and who, in addition, has



special training or expertise to evaluate the indications of the



examinations.



     In addition to the privileges for which broad qualifications are



needed, there are a number of specialties which require only limited



types of x-ray examinations.  For  example, a D.D.S. or D.M.D. may



request appropriate examinations of the head, neck, and chest, although



such requests are normally confined to the oral region.  Podiatrists



who have been granted clinical privileges may request x-ray



examinations appropriate to  their  specialty.



     It is recognized that medical students, interns, residents, and



some non-physician practitioners may not have developed medical



judgment as to which test would be most efficacious.  Such lack of



experience is remedied by work under conditions where there  is



sufficient expert supervision to monitor the prescription of



examinations and to provide  appropriate medical assistance.



     Variances to the above  qualification requirements should occur



only for emergency or life-threatening situations.  Non-peacetime

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                                  12




operations in the field and aboard ship would generally require such




variances wherein equipment designed for field use would need to be




operated by personnel available to perform necessary medical services.




Screening and Administrative Programs



     Many x-ray examinations are the result of screening programs or




administrative decisions, the reasons for which may no longer be




justifiable.  In general, such examinations are not preceded by




clinical evaluation by a physician to determine their need.  All




screening programs should be under the auspices of an appropriate




medical staff committee which annually reviews and affirms the need to




continue the program.  The annual review should eliminate all routine




or screening examinations which are not clinically justified.




     Chest x-ray examinations to screen for tuberculosis are not




justified except for certain high risk population groups  (2,3).  The




U.S. Public Health Service, the National Tuberculosis and Respiratory




Disease Association  (now the American Lung Association), the American




College of Chest Physicians, and the American College of Radiology have




publicly opposed such screening programs.  A review board should




establish that the expected incidence of tuberculosis is sufficiently



high in a population before a screening program is started.  The




radiation exposure and economic considerations suggest that the primary



screening examination for tuberculosis should be a tine or tuberculin




test even in populations exhibiting a higher than average incidence of

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                                   13



the disease  (4); radiological examinations should be used only to




followup clinical indications derived from such methods.




     Where chest x-ray  screening has involved large numbers of persons,




it has been  common practice to employ photofluorographic techniques to




save time and  expense.  This technique uses a fluoroscope to produce an




image of the chest which  is then photographed on 70 mm film.  Whereas




the procedure  is relatively fast and adaptable to examining patients




quickly at mobile stations, the exposure per examination is




considerably higher  than  an x-ray  examination performed on general




purpose equipment which produces standard-sized radiographs.  Also, the




size and quality of  the 70 mm film is such that only gross




abnormalities  can be diagnosed.  Although the technique was perhaps




justified a  few decades ago when there was a high incidence of




tuberculosis in the  United States,  the relatively higher exposure and




lower diagnostic yield  of this technique make its use generally




unjustified  even when chest x-ray  screening may be  justified.  Whenever




possible, Federal agencies should  not use photofluorographic equipment




to perform x-ray examinations.



     A routine chest examination for  hospital admission is not




suggested or presently  required by the guidelines of the Joint




Commission on  Accreditation of Hospitals.  A chest  examination is




currently not  justified as a  routine  requirement for hospital admission




due to the low yield of abnormalities diagnosed.  A recent  study of




routine screening in a  hospital population indicated that routine  chest

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                                  14



examinations, obtained solely because of hospital admission or



scheduled surgery, are not warranted in patients under the age of 20



and the lateral projection can generally be eliminated in patients



under age 40  (5).  Careful evaluations should be made of the need for



existing admission x-ray examinations and, of course, should precede



the institution of new ones.



     Other routine or screening x-ray examinations which should be



carefully evaluated are pre-employment lower back studies and routine



physical examinations which involve routine upper GI, barium enema,



gall bladder, and IVP examinations.  Examinations required by



legislation for certain high risk populations in order to establish



worker disability compensation should be evaluated carefully to



determine their continuing necessity.



     X-ray examinations which result in exposure of the fetus should be



avoided for pregnant women whenever possible (6).  Examples of



exposures of  pregnant women which may not be justified include routine



prenatal chest  and routine pelvimetry examinations.  When such women



have not received adequate prenatal care such examinations may well be



indicated.



Mammography




     Breast cancer is recognized as one of the  significant causes of



cancer death  in the United States.  Because of  the importance of early



detection in  control and survival, an increased emphasis on the use of



mammography has occurred.  This technique has improved considerably,

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                                  15




especially with respect to lowering exposure per examination with the




development of low-dose mammography and xeroradiography; however, even




at the current state of the art these techniques result in a dose of




several rads to each breast for a typical examination.  Whereas the




technique is justified to examine symptomatic women at any age, the use




of mammography to  screen asymptomatic women is still being seriously




examined by several groups, in particular the National Cancer Institute




and the American Cancer Society.  Asymptomatic women are defined as




those without complaint, without history, without physical findings,




and without a strong family history of breast cancer.  Symptomatic




women are those who exhibit a palpable breast mass, have skin changes,




or have a significant genetic or endocrinologic predisposition to




carcinoma of the breast.




     The American  College of Radiology formed a committee on




mammography which  recently evaluated mammography data accumulated from




the Health Insurance Plan in New York and the National Cancer




Institute.  On the basis of this evaluation, the Committee recently




made recommendations on mammography screening to the U.S. Food and Drug




Administration's Medical Radiation Advisory Committee for women in




three age categories  (7) .



     On the basis  of the ACR findings, it is recommended that




mammography should not be used routinely to screen asymptomatic women




under the age of 35 for breast cancer.  It is further recommended that




mammographic technique continue to be evaluated to obtain procedures

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                                  16




that represent an appropriate balancing between low exposures and




diagnostic accuracy.



     Current data on the effectiveness of mammographic screening for




breast cancer in asymptomatic women between the ages of 35 and 50 is



insufficient at this time to determine if such screening is justified.




The efficacy of routine mammographic examinations for this age group is




presently being studied through a joint screening project of the



American Cancer Society and the National Cancer Institute.  Because of




the continuing development of new information on mammography. Federal




agencies should periodically evaluate data from this study and others




in developing screening policies for this age group.




     Screening in asymptomatic women over 50 years of age appears




justified at this time.




Cancer Patient Evaluations




     In many health care facilities it is common practice for cancer




patients to receive extensive x-ray studies as part of their treatment



planning and followup.  Bagley, et. al., have reported the




effectiveness of several studies in managing the treatment of cancer




patients admitted to the National Institutes of Health  (8).  Their




findings indicate that once the primary diagnosis was made and




confirmed for some cancers, the results of routine x-ray studies such




as a barium enema and an upper GI series were found to have little




influence in the treatment of the patient.  These findings also suggest




that the yield of certain x-ray examinations is too low to justify

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                                   17




their use as a general screening tool for cancer evaluation.  Although




any study that would assist in the control of cancer in a patient can




be justified, such examinations should be generally productive in the




care and followup of a patient.  For this reason. Federal facilities




should periodically evaluate existing protocol studies to establish




those that are appropriate for evaluating patients with carcinomas.  In




this respect, the American College of Surgeons recently recommended




that tumor committees be  established to periodically review cancer




evaluations  and management  (9).




Dental Radiography




     One of  the most common radiographic procedures an individual is




likely to receive as a part of health care is a dental x ray.  A large




portion of the U.S. population visits a dentist one or more times each




year for routine checkups and associated dental care.  The 1970 X ray




Exposure Study estimated  that 661  million radiographic films were




produced in  1970 and of this number 279 million were dental films  (1).




     A patient presenting himself  to a dentist has a good chance of




receiving a  dental x ray  even though he may have no immediate dental




problems.  A study of dental radiography in Nashville, Tennessee




indicated that 57 percent of the facilities surveyed routinely do




interproximal examinations each year on regular patients and 21 percent




do a full-mouth series every 1 to  3 years; on new patients  58 percent




routinely do interproximal examinations and 64 percent selectively do a




full-mouth series  (10).   The mean  exposure per film in the  Nashville

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                                  18



study was 542 mR in 1972; after an educational program the mean dropped



to 340 mR per film, indicating the value of carefully controlled



procedures in reducing patient exposure due to dental radiography.



Because of the increased use of dental radiography in the U.S. it



appears reasonable to conclude that every effort should be exerted to



optimize the exposure per film and the number of films per examination.



     The proper decision to use x-ray studies in dental examinations



should be based on a requirement for proper diagnosis or definition of



disease and the number of radiographs should be the minimum necessary



to obtain the essential diagnostic information (11).  It is recommended



that dental radiographs be taken only after a dentist has examined the



patient and established by clinical indication the need for the x-ray



examination; neither a full mouth series nor a bitewing series is



justified as part of periodic preventive dental care.  This recom-



mendation is consistent with those of the American Dental Association



which also decidely disagrees with any requirement to provide post-



operative radiographs as proof of services rendered  (12).



     Dental radiography may be justified for forensic purposes for



certain high risk groups such as military personnel.  In such



circumstances it may be desirable to obtain a full mouth radiograph of



the teeth and jaw structure.



Self-referral Examinations




     A 1970 study indicates that approximately 30% of the medical x-ray



examinations in the U.S. were performed by non-radiologic clinicians

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                                  19




(1) .   Some examinations performed by non-radiologists may occur because



of the convenience of having the x-ray unit and the patient in the same




location, or, in the case of civilian contract services, need to




justify the equipment purchased or maintenance costs.  Self-referral




examinations are frequently performed by equipment operators lacking




adequate training and physician supervision by clinicians with



inadequate radiologic experience.




     Patients are sometimes referred to another health care facility




for medical care and previous x-ray examinations conducted at the first




facility will be repeated.  In a primary care facility, only the




studies needed for appropriate referral should be performed.  When




examinations have been conducted prior to referral, these x-ray films



should accompany the patient to minimize the need for additional




diagnostic x-ray examinations and resulting patient exposure  (13) .




     Unnecessary radiation exposure caused by self-referral practices




generally need not occur  in Federal health care installations where




facilities staffed by radiologists are normally provided.  Exceptions




could be small operational units such as ships, field units, or




isolated stations where the normal work load does not justify a staff




radiologist.  Thus, the conduct of self-referral x-ray examinations




should be permitted only  for a physician whose qualifications to




supervise, perform, and interpret diagnostic radiologic procedures have




been demonstrated to the  appropriate authorities.

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                                  20




     It is recognized that limited self-referral type examinations are




performed in Federal medical centers in certain clinical specialties.




In such situations, the examinations performed should be unique to the




specialty.  Such examinations should be performed only by qualified




personnel and peer review policies should exist to assist in




eliminating unproductive practices.




     Self-referral practices in contract civilian facilities should be




prohibited since such practices have been shown to lead to




overutilization (14).  Exception may be made in remote areas where no




practicable alternative exists.

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                       PROCEDURAL CONSIDERATIONS








     Although the largest reduction in radiation exposure is to prevent



the ordering of an unproductive x-ray examination, patient exposure can




also be reduced by the diagnostician by careful consideration of the




numbers and types of radiographs to be taken during the examination




(15).  These considerations can also be classified as prescription




decisions.  In conducting x-ray examinations, therefore, the




diagnostician should be capable of making the best diagnosis possible




and be aware of the quantity and potential risk of the radiation he is




administering.




General Considerations and Review Plans




     Each x-ray examination should be as objective-related as possible



to accomplish the diagnosis with the minimum amount of exposure.  Most




x-ray departments establish a set of standard examination procedures




which specify the number and types of radiographic views to be taken




when the procedure is performed.  A periodic review of all standard



examination procedures should be performed to determine if the




established routine is achieving the objectives and whether




modifications are warranted.  Continuation of a standardized




examination procedure should be predicated on satisfying the following




criteria: a) the efficacy of the examination is sufficiently high to




assure that the diagnosis could not have been made with less risk by




other non-radiological means or a lower number of views, b)
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consideration of the previous similar examinations performed with



multiple views established that in a significant number of the cases



all views were necessary for the diagnoses rendered, and c)  the yield



of the examinations offsets the radiation exposure delivered.



     A periodic review of standard operating procedures should be made



at least annually by the appropriate medical or dental staff committee



with the advice of referring physicians.  Such reviews should consider



the consensus and advice of professional societies concerning the



efficacy of radiologic exams.



Minimum Number of Examinations and Views



     A written outline containing the minimum number of views to be



obtained for each requested examination should be made available to



each clinician and equipment operator in every radiology facility.



Beyond the specified minimum views, the examination should be



individualized according to a patient's needs.



     All examinations should be tailored to the individual department



taking into account the equipment available.  In some instances,



certain examinations should be done only on certain types of equipment.



     The outline of procedures should indicate who may authorize



deviations from the standard set of views for any examination.  Every



effort should be made to reduce to a minimum the number of standard



views for any examination.  The necessity of additional views, such as



comparison views, should be determined by the radiological



diagnostician.  Follow-up for examinations should be done at reasonable

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time intervals so that significant changes in clinical information are




obtained for making proper decisions on continuation or alteration of




the management of the patient.




Patient History and Physical Condition




     Whenever possible a radiologist should review all examination




requests requiring fluoroscopy or multiple film studies, especially




those associated with tomography or scanning techniques, before the




examination is given and preferably before it is scheduled  (16).  For




this reason, it is important that a thorough and accurate patient




history be included with each examination request.  Based upon a review




of  the history and previously documented studies, the radiologic




diagnostician should direct the examination to obtain the diagnostic




objective stated by the referring clinician through the addition,




substitution or deletion of views.  It is preferable that changes in




the examination be done in consultation with the requesting clinician.




     Another means by which the radiologic diagnostician may reduce




patient exposure is to avoid any repeat examinations due to improper




patient preparation for contrast media studies.  Miller has reported




that poor bowel preparation is a frequent cause of marginal or repeated




contrast media studies of the lower GI tract  (17).  The radiology




department can minimize the number of marginal studies by instituting




appropriate pre-examination procedures  (13).  These procedures should




include assuring that patients have had the appropriate laxatives and




enemas prior to performing contrast media studies of the lower GI

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tract.  It may also be advantageous to place bedridden, elderly, or




constipation-prone patients on low-residue diets several days before




scheduling the studies.  Determination that a patient has had previous




surgery before GI tract examinations could also help minimize the




number of marginal studies.  Similarly, the prior determination that a




patient had taken any prescribed oral contrast media would prevent




unnecessary retakes of such studies.

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                       EQUIPMENT CONSIDERATIONS








     Once the physician or dentist determines that the prescription of



an x-ray examination is warranted for diagnostic purposes, other




factors become important in limiting patient exposure.  These factors




are the design of good x-ray equipment, equipment use, and the




assurance that equipment operators have received adequate training to




perform the examination without unnecessary exposure to himself or the



patient.




Equipment Use Policy




     The utilization and supervision policy of medical and dental x-ray




equipment should be approved by the responsible facility authority upon



the recommendations of medical and dental staff.




     Criteria for the supervision of medical x-ray equipment should




also be established in each facility in a written policy.  The formal




policy should be reviewed annually by medical staff committees and by




those departments whose members have privileges in radiology.  The




definition of privileges in radiology should be made in terms of the




needs of the patients served by that facility, recognizing that the




availability of optimally trained physicians and the varying levels of




service and training will make each circumstance different.




     Types of medical personnel eligible for utilization of x-ray




equipment may be classed as physicians, ancillary personnel, and




radiological technologists.  Eligible physicians include radiologists
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and other physicians granted privileges in radiology.   Such privileges



might include the use of x-ray equipment by cardiologists for cardiac



catheterizations and by dentists or podiatrists as part of their



practice.  Before physicians and dentists are granted radiology



privileges they should have received adequate training in equipment use



and radiation protection.  However, specific protocols establishing the



limit of radiology privileges to specified types of physicians or



dentists should be part of the written policy statement.



     The use of x-ray equipment by ancillary personnel such as



radiation physicists and repairmen should be limited to testing and



evaluating equipment performance.



     Radiographic technologists are by far the largest group to



directly utilize x-ray equipment.  Eligibility to operate general



purpose x-ray equipment should be granted only to registered (ARRT)



technologists or those with equivalent training.  Technologists in



training should be eligible to utilize equipment only while under the



supervision of a registered technologist.  "Limited privilege"



technologists not having registration, equivalent training, or



supervision by a registered technologist may perform selected



examinations under the direct supervision of physicians granted



radiology privileges.  "Limited privilege" technologists include those



who perform single or limited studies such as operating a photo-timed



chest unit.

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                                  27



     The utilization of dental x-ray equipment should be under the



supervision of a licensed dentist.  Dental care personnel such as



dentists, dental hygenists, dental assistants, and dental technologists



should only perform dental x-ray examinations after proper training.



The training should include proper tube positioning and film placement,



technique selection, film processing techniques, and a thorough review



of radiation protection principles.  The training in film processing is



to be stressed since a common error in dental radiography is to



overexpose and underdevelop a film, thus leading to excessive patient



exposure.



     Other medical personnel such as nurses and laboratory



technologists should not be eligible to operate x-ray equipment.  Their



use of such equipment could be warranted only in a life saving or



threatening situation during which qualified personnel as specified



above are not available to perform the examination.



General Radiographic Equipment



     The Nationwide Evaluation of X-ray Trends survey has demonstrated



that the same technique factors used with different x-ray generators



may produce widely varying patient exposures.  Thus, the performance of



x-ray equipment utilized for diagnostic x-ray procedures is an



important factor in limiting patient and operator exposure.  The



Federal Diagnostic X-Ray Equipment Performance Standard  (21 CFR



Subchapter J) requires that x-ray equipment manufactured after August



1, 1974. be certified by manufacturers to comply with performance

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                                  28




standards issued by the U.S.  Department of Health, Education, and




Welfare pursuant to the Radiation Control for Health and Safety Act of




1968 (PL 90-602).



     All Federal health care facilities which perform diagnostic x-ray




examinations should, as soon as readily achievable, utilize medical and




dental x-ray equipment that conforms to the requirements of 21 CFR




Subchapter J.  It is possible to obtain variances for special medical




and dental x-ray equipment purchased after August 1, 1974; however.




Federal use of this variance should be minimized.




     All existing, non-certified equipment being used is not




necessarily substandard.  In order to preclude substantial economic




costs involved with large-scale replacement or retrofit of all non-




certified equipment, while still providing for the elimination of



equipment which is determined to be sub-standard with reference to




currently accepted radiation safety standards, it is recommended that




all non-certified medical and dental x-ray equipment meet the criteria




in parts F.4, F.5, F.6, and F.7 of "Suggested State Regulations for




Control of Radiation  (18)."  Whereas the above criteria do not meet the




rigid requirements for certification according to the Federal




performance standard, they provide adequate conformance with those




parameters which affect radiation protection of the patient and




operator.  Assurance that the x-ray generator meets the "Suggested




State Regulations for Control of Radiation" can be demonstrated with




test equipment considerably less complex than that required to

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                                  29




demonstrate compliance with the equipment performance standards for x-




ray equipment required by 21 CFR Subchapter J.




     Certain sections of the x-ray equipment performance standard




provide for planned obsolescence, such as the provision which permits




the use of non-certified components as replacement items in equipment




manufactured before August 1, 197U.  Although such use of non-certified




replacement components is permitted until August 1, 1979, their use




should be justified.  Stockpiling of either x-ray equipment or




components should  also be minimized, since the technological advances




in x-ray equipment tends to preclude its use.




     To insure that x-ray equipment used is justifiably representative




of present day technological advances, authorities should develop and




periodically review a planned replacement schedule for all types of




diagnostic x-ray  equipment used in their programs.




Fluoroscopic Equipment Policy




     X-ray equipment should not exceed the medical mission of the




facilities, i.e.,  fluoroscopy should not be available in facilities




where qualified medical  personnel are not assigned.  This will serve to




deter one source  of unproductive radiation exposure.



     Although the aggregate population dose is larger from the use of




general purpose diagnostic equipment, the highest exposures to




individuals are generally associated with fluoroscopic examinations.




Fluoroscopic examinations require large  exposure rates for periods of




time long enough  to observe dynamic changes;  thus, it is of utmost

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                                  30



importance that Federal health care facilities give particular



attention to minimization of fluoroscopic examinations.



     Because the reduction of patient exposure is considerable and the



additional cost of image-intensified units is justifiable, fluoroscopic



units which do not contain image-intensification systems should not be



used.  The retention of older non-image intensified units for the



reason that they may not be used with great frequency should not be



permitted because the patient exposure rates are an order of magnitude



greater than intensified units.  If the medical mission requires



fluoroscopy, only image-intensified units operated by those with



demonstrated competence should be permitted.



     Specialized procedures (hip replacements, transphenoid



hypophysectomy, biopsy and cannulizations via fibro optic scopes)  may



require fluoroscopic assistance.  In order to provide fluoroscopic



assistance for such special procedures and to minimize patient



exposure, non-radiological specialists such as orthopedists,



neurosurgeons, gastroenterologists, cardiologists, chest surgeons, etc.



should where practicable only use equipment with electronic image



holding features such as pulsed video-hold or equipment with similar



low-exposure features.  The advantage of such units is that the



radiation exposure is about one-twentieth of that from continuous



fiuoroscopy and yet the image is adequate.



     Non-radiologists who operate a special fluoroscopic unit should



take a course of instruction in radiation safety which meets guidelines

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                                  31




established by responsible authority and demonstrate competence in the



use of this equipment.  Such courses of instruction should be




considered as a standard part of the training program for physicians




who may have occasion to use such equipment in their practice.  Use of




pulsed video-hold or similar dose-saving special equipment should be




approved by a senior radiologist in order to prevent use of such units




for studies other than  those for which they were designed.

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                              REFERENCES
1.   Population Exposure to X rays U.S. 1970, DHEW Publication No.
     (FDA)  73-8047, November 1973.

2.   The Chest X-ray as a Screening Procedure for Cardiopulmonary
     Disease, Policy Statement, DHEW Publication No.  (FDA) 73-8036,
     April 1973.

3.   "Chest X-ray Screening Recommendations for TB-RD Associations,"
     NTRDA Bulletin, October 1971.

4.   Ochs, C.W., "The Epidemology of Tuberculosis", JAMA, Vol. 179, pp.
     247-252, January 27, 1962.

5.   Sagel, F., et. al., "Efficacy of Routine Screening and Lateral
     Chest Radiographs in a Hospital-Based Population," N. Engl. J.
     Med., Vol. 291, No. 19, November 7, 1974.

6.   Protection Against Ionizing Radiation From External Sources,
     International Commission on Radiological Protection, Pergamon
     Press, p. 19, 1969.

7.   Minutes, 13th Meeting of Medical Radiation Advisory Committee,
     U.S. Food and Drug Administration, Bureau of Radiological Health,
     Rockville, Maryland, May 1975.

8.   Bagley, D.H., et. al., "Barium Enema, Proctosigmoidoscopy, and
     Upper Gastrointestinal Series in the Preoperative Evaluation of
     the Cancer Patient," Surgery Branch, National Cancer Institute,
     Bethesda, Maryland  (To be published).

9.   Position Statement on Cancer Patient Care Evaluation, American
     College of Surgeons, Chicago, Illinois, December 1, 1975.

10.  Crabtree, C.L., et. al., Nashville Dental Prelect: An Educational
     Approach for Voluntary Improvement of Radiograph!c Practice, DHEW
     Publication No.  (FDA) 76-8011, July 1975.

11.  Chamberlain, R.H., A Practical Manual on the Medical and Dental
     Use of X-ray with Control of Radiation Hazards,  The American
     College of Radiology, Chicago, 1958.
                                   32

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                                   33

12.  Council on Dental Materials  and  Devices,  "Recommendations in
     Radiographic Practices," JADA Vol.  90,  pp.  171-172,  January 1975.

13.  "Memorandum on  Implementation of the Second Report of the Adrian
     Committee on Radiological  Hazards to Patients," Brit. J.  Radiol.
     Vol. 37, pp.  559-561,  1964.

14.  Childs, A.W., and Hunter,  E.D.,  Patterns  of Primary Medical Care -
     Use of Diagnostic X-ray  by Physicians,  Working Paper No.  10,
     Committee on Health Economics and Administration,  Institute of
     Business and Economic  Research,  University of California - Berkley
      (1970) .

15.  Payne, F.W., "Physicians,  Radiologists, and Quality Control,"
     Proceedings  of  the  1972  Radiological Health Section, American
     Public Health Association, DHEW  Publication No. (FDA) 74-8002,
     Bureau of Radiological Health, Rockville, Maryland.

16.  Abrams,  H.L., "Observations  on the Manpower Shortage in
     Radiology,"  Radiology, Vol.  96,  pp. 671-674, 1970.

17.  Miller,  R.E., "The  Clean Colon," Gastroenterology, Vol. 70, No. 2,
     pp. 289-290,  1976.

18.  Suggested State Regulations for  Control of Radiation, prepared by
     The Conference  of Radiation Control Program Directors in
     cooperation  with the U.S.  Atomic Energy Commission and the U.S.
     Food and Drug Administration, Published by FDA-Bureau of
     Radiological Health, Rockville,  Maryland, October 1974.
     4 U. S. GOVERNMENT PRINTING OFFICE • 1976 —627-l63/9a
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