Journal of Engineering and Public Policy
(Vol. 9, August 2002)

Mandatory Licensure of Radiologic Personnel

By Christopher Jason Tien

Executive Summary

The public has considerable concern regarding risks from radiation exposure – mostly from the 103 operating nuclear power plants and the newly proposed power plants. Yet, less than one percent (1%) of public radiation exposure is attributable to the normal operation of the nuclear power plants. In fact, 90% of the public exposure to man-made ionizing radiation results from medical procedures, primarily from diagnostic examinations (ASRT). For example, one patient receives more radiation from an x-ray examination of the abdomen than the entire exposed public received from the Three Mile Island. Additionally, The National Cancer Institute estimates that the long-term effects of overexposure to radiation during diagnostic x-ray examinations alone may be responsible for more than 3,500 cancer deaths a year. Annually, for more than 300 million Americans, quality health care begins with quality radiologic care (Legislative).

The scope of this paper will be limited to ionizing radiation, as that is the “typical” aspect of radiological procedure. Furthermore, this paper will consider only radiologic technicians and technologists as radiologic personnel because 90% of the time it is the technician who measures out the dosage and/or delivers the physical dosage to the patient. It is important to note that there are other radiological personnel in the hospital such as medical physicists, radiologists, and nuclear medicine specialists. However, these personnel are already licensed.

Congress passed the Consumer-Patient Radiation Health and Safety Act in 1981, calling for minimum education standards for operators of x-ray equipment. The passage of this law mandated states to establish minimum standards for operators of ionizing radiation equipment. Unfortunately, compliance with this law is voluntary and there are no penalties for not following this Federal recommendation. In order to protect the health of more than 350 million of people receiving radiologic procedures annually from the potential hazards of radiation diagnostic and radiation therapy procedures, licensure is necessary for all radiologic personnel.

Not surprisingly, an estimated 40% of operators administering ionizing radiation have no formal education in radiologic technology (Legislative). Additionally, 11 states have opted out of the federal standards completely. In other words, in almost 24% of our states (including the District of Columbia), individuals are not legally required to demonstrate any level of competence before being allowed to administer potentially dangerous doses of radiation to patients. Although highly unlikely, literally anyone off of the street can be hired one morning and be operating this potentially dangerous equipment the same afternoon.

The federal government regulates the equipment that the hospital uses through the Nuclear Regulatory Commission and, to a lesser degree, the Food and Drug Administration’s Bureau of Radiological Health. However, neither organization regulates the technicians that operate the equipment. This situation is somewhat analogous to a car: like your car, the operator determines the use and abuse of this equipment. No one would permit his or her car, even with all of its safety features, to be operated by someone who was not properly licensed.

It has been shown that certified radiologic personnel deliver lower dosages (Brody) (Ionizing) (ASRT) (Legislative). Specifically, a patient undergoing the same x-ray examination may receive 100 times more radiation depending on the skill-level of the operator of the equipment. Similarly, comparing the number of NRC misadministrations per capita, there is an entire order of magnitude difference (per year per million people) between licensed vs. unlicensed states. This same trend appears when comparing states which have changed status from unlicensed to licensed.

During a 10-year period of licensure for California, overall medical fees increased 92.7% throughout the state, while fees for radiology services increased only 59.2%. Regulation would not increase health care costs; rather, it would reduce costs by ensuring quality exams performed by knowledgeable radiologic technologists; capable of reducing not only radiation exposure to the consumer-patient, but also in reducing waste of medical supplies, technologist and patient time, and the wear of radiologic equipment from improper use. Approximately $1.5 billion is wasted annually on unnecessary, repeated x-ray procedures alone – not including the money lost due to potential patient flow, or other opportunity costs (Legislative).

The 1981 Consumer-Patient Radiation Health and Safety Act should be updated to include “mandatory compliance” with the federal standard. The next step is to establish a credible federal standard. The next-generation NRC “agreement-state” program should be set in motion, in addition to giving the NRC enforcement power. Continuing competency in the form of continuing education and random audits and inspections are also essential.

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