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ACT 304 AND RELATED
REGULATORY REQUIREMENTS
            IN
 DIAGNOSTIC RADIOLOGY



    Muhammad Khalis Bin Abdul Karim
    Radiation Health and Safety Unit
     Johor State Health Department
       Ministry of Health Malaysia
Contents
Background
Atomic Energy Licensing Act 1984
(Act 304)
Subsidiary regulations under Act 304

Regulatory and Licensing
Requirements in Diagnostic Radiology
Part I


Background
Legislation Hierarchy

            1      Act

                      Regulations                                     Legally
            2                                                         Bound

                          Circulars/ Standards
            3             & Code*
                              Local Rules,
            4                 Guidelines,                             Voluntary
                              Instructions Manual

* Not regulatory by itself but becomes regulatory if linked to Regulations/Acts
In the numbers
(1)
                 6,570 radas
Malaysian Legislation
Radioactive Substance Act 1968
- First legislation regulating the use of
  ionising radiation.
- MOH control the use of ionising radiation
  for medical and non-medical

Atomic Energy Licensing Act 1984 (Act 304)
- Replaces and supersedes Radioactive
  Substance Act 1968.
- Act under MOSTI
Cont..
•   Act 304 was gazetted under the purview of
    Ministry of Science, Technology and Innovation
    Malaysia (MOSTI).

•   The Director-General of Health where the activity
    to be licensed under this Act is in respect of the
    use of ionizing radiation for medical purpose as
    determined in Section 15 (2) Act 304.

•   RHSS, MOH is entrusted as the secretariat for
    the D-G of Health, in all activities that related to
    the use of ionising radiation for medical
    purposes.
Regulatory Authority

               Atomic Energy Licensing Board (AELB)
                      (Regulatory Authority)
                                  Authority



         Medical                        Non-Medical
      Ministry of Health            Ministry of Science, Tech and
          Malaysia                       Innovation (MOSTI)


  Director General of Health         Executive Secretary to the
   (Regulatory Authority)
               Authority                      Board

         Secretariat:                       Secretariat :
Radiation Health & Safety Section           AELB (Dept)
          (RHSS), MoH
Malaysian Legislation
Main Act
Atomic Energy Licensing Act 1984 (Act 304)

Subsidiary Regulations
 Radiation Protection (Licensing) Regulations
  1986
 Atomic Energy Licensing (Basic Safety
  Radiation Protection (Basic Safety Standard)
  Radiation Protection) Regulations 2010
  Regulations 1988
 Radiation Protection (Transports)
  Regulations 1989
Malaysian Legislation
             Guidelines/Circulars

 Malaysian Standards (MS 838) : Code of Practice
   For Radiation Protection (Medical X-Ray Diagnosis)
   - 1985 (1st Revision, 2007)
 Circular on Employment of Trained X-Ray
   Operators By Private General Practitioners - 1993
 Guidelines To Obtain Class C License Under the
   Atomic Energy Licensing Act 1984 - 1994
 Guidelines For Medical Diagnostic Procedures
   Using X-ray For Women of Childbearing Potential -
   1998
Malaysian Legislation
Continue..

  Circulars on Licensing Requirements Under Act 304
     For Specialized Diagnostic Radiology Services
     Provided by Private Hospitals/ Radiology Clinics –
     1999
  Circulars on Licensing Requirements Under Act 304
     For Specialised Diagnostic Radiology Services
     Provided by GP Clinics - 1999
  Circulars to TKPK(Medical), TKPK(Public Health) &
     Pengarah Perancang & Pembangunan – 2001
  Guidelines On The Use of Mobile X-ray Machines -
     2005
Part II




     Atomic Energy
Licensing Act (Act 304)
Atomic Energy Licensing Act 1984
Contents
  Atomic Energy Licensing Board, functions, powers
• Control and licensing

• Cancellation, Suspension and Renewal of Licenses

• Health and Safety

• Disposal of Radioactive Waste

• Power of seizure and Arrest, Offences and
  Forfeiture
• Liability for Nuclear Damage
Act 304


    Appropriate Authority

a) The Director-General of Health
   where the activity to be licensed or
   licensed under this Act is in respect of
   a medical purpose

b) The Board where the activity to be
   licensed or licensed under this Act is
   in respect of a purpose other than a
   medical purpose

        Sec 2 of Atomic Energy Licensing Act 1984
Act 304

        Control and licensing
12.(1) Without prejudice to the requirements
of any other law, no person shall :
  a) site, construct or operate a nuclear
     installation
  b) deal in, possess or dispose of any
     radioactive material, nuclear material,
     prescribed substance or irradiating
     apparatus

 unless he is the holder of a valid license
Act 304



12.(3) A licence for using any any
radioactive material, nuclear material,
prescribed substance or irradiating
apparatus for diagnostic or therapeutic
purposes may be issued ONLY to a
registered medical practitioner,
registered veterinary surgeon,
radiologist, radiotherapist or registered
dentist
Act 304



  Condition of Licenses


17(1) Licenses issued under this Act
shall be subjected to such conditions as
may, be imposed by the appropriate
authority which may in respect of the
conditions imposed by it, add to, vary
or revoke such conditions at any time.
Act 304
      Cancellation, Suspension and
          Renewal of Licenses
22(1) The appropriate authority may at any time
under any of the following circumstances in its
discretion cancel, or suspend any license ;
 a) Where the licensee has committed an offence
    under this Act
 b) Where the licensee has committed a breach of
    any of the conditions of the license
 c) Where the licensee ceases to work or operate the
    nuclear installation in respect of which the license
    was issued
 d) Where in the opinion of the appropriate authority
    it would be in the public interest so to do
In the numbers
(2)                  660
                 radas penyinaran
In the numbers
(3)                279
                 premis swasta
Act 304

           Health and Safety
25 (1) Every licensee shall comply with all
such directives as the appropriate authority
may issue…, including :
a) Conditions of exposure
b) Dose limitation
c) Occupation exposure
d) Medical exposure
e) Exposure of members of the
   public
f) Accidental exposure
g) Emergency exposure
Act 304

25 (2) If the appropriate authority has reasonable
cause to believe that any workers has been or
likely to be exposed …, licensee shall :

 a) provide and require such worker to wear
    approved personnel monitoring devices
 b) keep records of dose and type of ionizing
    radiation
 c) install or use monitoring devices in work
     places to record the amount of ionizing
     radiation present
 d) provide medical examination for such worker
Act 304


   Disposal of Radioactive Waste

26 (1) No person shall dispose of or
cause to be disposed any radioactive
waste without the prior authorization in
writing of the appropriate authority
Act 304

    Powers of Seizure and Arrest,
      Offences and Forfeiture
33 (1) & 34 (1) Senior Public Officer authorize
to, with or without warrant :
a) Enter the premises, site, nuclear installation or
   conveyance and there to search and seize such
   radioactive material, nuclear material, prescribed
   substance, irradiating apparatus, book or document;

b) Arrest any person being in or on the premises, site,
   nuclear installation or conveyance in whose
   possession or under whose control such radioactive
   material, nuclear material, prescribed substance,
   irradiating apparatus, book or document is found;
Act 304


33(2) Senior Public Officer may if necessary,
with or without assistance:-
•   Break open any door or window or part of the
    premises, site, nuclear installation or conveyance and
    there to have ingress thereinto;
•   Forcibly enter the the premises, site, nuclear
    installation or conveyance
•   Remove by force any obstruction to entry, search,
    seizure and removal as he is empowered to effect
d) Detain every person found in or on the
   premises, site, nuclear installation or
   conveyance until the premises, site, nuclear
   installation or conveyance has been searched
Act 304



38(1) Any radioactive
material, nuclear material,
prescribed substance,
irradiating apparatus or
radioactive waste in respect
of which an offence under
this Act is committed, or any
book, document or
conveyance connected with
such offence is liable to
forfeiture
Act 304


               Offences
39 – Specific offences [(a) – (i)] under this
Section is, on conviction, liable to
imprisonment for a term not exceeding 5
YEARS or a fine not exceeding RM10,000 or
BOTH

40(2) Any person who commits an
offence under this Act is liable to
imprisonment for a term not exceeding
10 YEARS or a fine not exceeding
RM100,000 or BOTH
Part III

  Subsidiary Regulations
     under Act 304
 Radiation Protection (Licensing)
  Regulations 1986
 Atomic Energy Licensing (Basic Safety
  Radiation Protection) Regulations 2010
 Draft Radiation Protection (Medical, Dental
  and Veterinary Usage of Radiation)
  Regulations 201__
Radiation Protection (Licensing)
         Regulations 1986
Contents
 Classification of licenses
 General Conditions for Obtaining a
  License
 Application for, Amendment and
  Renewal of License
 License fees

  -   Review fees and application forms – one form for all
      type of application, etc
       – still in JKK of LPTA
Classification of Licenses
          A license to manufacture, trade in, produce, process,
Class A   purchase, own, possess, use, transfer, handle, sell or
          store radioactive material


          A license to manufacture, trade in, ..… or store nuclear
Class B   material

          A license to manufacture, trade in, ….. or store irradiating
Class C   apparatus

          A license to transport radioactive material, nuclear material,
Class D   prescribed substances or their waste

          A license to export or import radioactive material, nuclear
Class E   material, prescribed substances, irradiating apparatus or
          their waste
Cont..

            A license to site, to construct or to operate a nuclear
  Class F   installation

            A license to
            •     dispose of radioactive material, nuclear
  Class G         materials, prescribed substances or their wastes
            •     store of radioactive material, nuclear materials,
                  prescribed substances or their wastes prior to
                  their disposal
            •     Decommission a milling installation, nuclear
                  installation, waste treatment facility, irradiating
                  apparatus or sealed sources apparatus

            A license to control of activities not covered by classes
  Class H   A to G
General Conditions For
         Obtaining a Licenses
12 (a) The applicant shall employ a person or persons
       having the necessary knowledge, skill and
       training to ensure that the activities sought to
       be licensed are carried out in such manner as to
       protect the health of workers and members of
       the public
   (b) The applicant’s proposed equipment, facilities
       and procedures shall be adequate to protect the
       health of workers and member of the public and
       to minimize danger to life, property and the
       environment
License & Application Fees
    Category/Type of Irradiating
                                          License fee per year in RM
            Apparatus

     Dental X-ray units, mobile &    RM100 for the first apparatus
1    fixed medical x-ray units,
     mobile veterinary X-ray units   RM20 for every additional apparatus


     X-ray therapy units not         RM300 for the first apparatus
2
     operable above 500kVp           RM60 for every additional apparatus

     CT Scanner units,               RM1000 for the first apparatus
3    Accelerators, X-ray therapy
     units operable above 500kVp     RM200 for every additional apparatus

          Application Fee            RM15



          Reg 15 of Rad. Protec (Licensing) Regulations 1986
Cont..

         Category of Sealed Source               License fee per year in RM

                   1
                                            RM100 for the first source
Any sealed source with activity not greater
                                            RM20 for every additional source
              than 40MBq

                    2
                                              RM200 for the first source
   Radiation gauges and other sealed
                                              RM40 for every additional source
  sources not specified in this Schedule

                    3
                                              RM300 for the first source
 Medical therapy sources with activity not
                                              RM60 for every additional source
       greater than 400MBq, etc

                      4
   Medical therapy sources with activity      RM1000 for the first source
  greater than 400MBq, irradiation cell for   RM200 for every additional source
        sterilization purposes, etc

              Reg 15 of Rad. Protec (Licensing) Regulations 1986
In the numbers
(4)              21
                 CT Scan
Atomic Energy Licensing (Basic
 Safety Radiation Protection)
      Regulations 2010



         15 February 2010
OLD                             NEW
      Radiation                    Atomic Energy
  Protection (Basic      VS
                                  Licensing (Basic
  Safety Standard)                Safety Radiation
  Regulations 1988                   Protection)
                                  Regulations 2010


 Based on ICRP 26,            Based on ICRP 60,
  1977                            1990
 56 provisions                  80 provisions
 Medical Exposure – 5           More provisions on
  provisions                      Medical Exposure –
                                  18 provisions
Interpretation
“medical exposure” means the exposure
          exposure
incurred by :

(a) a patient as part of his medical or dental
    investigative or diagnostic procedures or
    treatment;
(b) a person who knowingly assists in the
    support and comfort of patients, other than
    a person who is occupationally exposed; or
(c) a volunteer in a medical research
    programme that involves radiation
    exposure;
                                           Reg. 3
Atomic Energy Licensing (Basic Safety Radiation
              Protection) Regulations 2010


         ARRANGEMENT OF REGULATIONS
PART I     - PRELIMINARY

PART II    - SYSTEM OF RADIATION PROTECTION

PART III   - OCCUPATIONAL EXPOSURE

PART IV    - MEDICAL EXPOSURE

             Specific provisions in diagnostic radiology
             •   Requirements for irradiating apparatus and equipment
                 using sealed sources for diagnostic radiology
             •   Operational consideration for diagnostic exposure
             •   Clinical dosimetry
             •   Quality assurance for medical exposure
             •   Guidance levels
             •   Investigation, notification and reporting of accidental
                 medical exposure
Cont..

          ARRANGEMENT OF REGULATIONS


PART V    - PUBLIC EXPOSURE

PART VI   - POTENTIAL EXPOSURE AND SAFETY OF RADIATION
            SOURCES

PART VII - INTERVENTION

PART VIII - SUBMISSION OF DOCUMENTS

PART IX   - CESSATION OF OPERATIONS, DECOMMISSIONING OR
            ABANDONMENT OF LICENSED FACILITIES

PART X    - GENERAL
PART I     - PRELIMINARY


Working Area
Classification of             Clean Areas, Supervised Areas
Working Areas :               and Controlled Areas

“clean area” - an area where the annual dose received by a
         area
worker
is not likely to exceed the dose limit for a member of the public;
“controlled area” - area in which specific protection measures and
            area
safety provisions are required for controlling normal exposures or
preventing the spread of contamination during normal working
conditions, and preventing or limiting the extent of potential
exposures;
“supervised area” - an area for which occupational exposure
            area
conditions are kept under review even though specific protective
measures and safety provisions are not normally needed;
                                        Reg. 3
PART III   - OCCUPATIONAL EXPOSURE


Classification of Working
Area
Supervised Areas and Controlled
Areas have to clearly demarcated
and appropriate legible notices
and warning signs bearing the
radiation symbol are posted
conspicuously in strategic places.
Question
Where is the area considered as controlled
area in a diagnostic imaging department ??
PART II   - SYSTEM OF RADIATION PROTECTION


Dose Limit for Workers &
Member of Public
                               Whole Body Exposure
                               Dose Limit (mSv/year)
                           BSS 1988            BSS 2010
Public                            1                  1
Radiation Workers                50                 20*
Foetus                           10                  1

* The maximum effective dose on the worker averaged over a
  period of 5 consecutive years shall not exceed 20mSv

                                                       Reg. 8 & 9
Question
What is the patient dose limit ?

A:     1 mSv/year                  Public

B:     20 mSv/year        Radiation workers
                        (new BSS Regulations
                               – 2010)
C:     50 mSv/year

D:     150 mSv/year       Radiation workers (old
                          BSS Regulations 1988)

ANS:     NO LIMIT
                         Lens of the eyes
Personnel Monitoring
(1) The licensee shall be responsible for arranging the
    assessment of the occupational exposure of workers
(2) The licensee shall carry out personnel monitoring for all
    workers who normally work in a controlled area, and
    workers who occasionally work in a controlled area but
    may receive significant occupational exposure.
(3) Personnel monitoring shall not be required for any
    worker who normally works in a supervised area, or
                                                area
    who enters a controlled area only occasionally, but the
    occupational exposure of the worker shall be
    assessed on the basis of the results of work place
    monitoring


                                                       Reg. 22
PART IV   - MEDICAL EXPOSURE

Responsibilities of licensee or
employer
To ensure that :
(a) no patient is administered with a diagnostic or
    therapeutic medical exposure unless the exposure
    is prescribed by an approved registered medical
    practitioner;
(b) an approved registered medical practitioner is
    assigned with the primary task and obligation of
    ensuring overall patient protection and safety in the
    prescription of, and during the delivery of,
    diagnostic or therapeutic medical exposure to the
    patient;
                                                     Reg. 41
Cont…

(c) an appropriate healthcare professional who is
    adequately trained to discharge assigned tasks to
    the patients in the conduct of the diagnostic or
    therapeutic procedures that the approved registered
    medical practitioner prescribes, is available;
(d) for diagnostic uses of radiation, the quality
   assurance programme specified by the appropriate
   authority is conducted by or under the supervision
   of a qualified expert in medical physics;
Operational consideration for
diagnostic exposure
(1) For diagnostic radiology practices, the licensee
shall ensure:
(a) the exposure of patients is at the minimum level
    required in order to achieve the intended diagnostic
    objective;
(b) the relevant information from previous examinations
    is taken into account in order to avoid unnecessary
    additional examinations; and
(c) the relevant guidance levels as specified in the Sixth
    Schedule is taken into account.


                                                       Reg. 48
Cont…

The licensee shall ensure that …

the diagnostic procedure chosen to produce the
minimum exposure to patient is consistent with the
acceptable image quality and the clinical purpose of the
examination.

the portable and mobile radiological equipment is used
only for examinations where it is impractical or not
medically acceptable to transfer patients to a stationary
radiological installation, and only after proper attention
has been given to the radiation protection measures
that are required in its use.
Cont…
The licensee shall ensure that …
any radiological examination causing exposure to the
   abdomen or pelvis of women who are pregnant or
   suspected to be pregnant is avoided, unless there are
                                  avoided
   strong clinical indications for such examinations.
any diagnostic examination of the abdomen or pelvis of
   women of reproductive age is planned to deliver the
   minimum dose to the ovary or to any embryo or foetus
   that might be present.
whenever feasible and appropriate, shielding of
  radiosensitive organs such as gonads, lens of the eye
  and thyroid is provided.
                 provided
Clinical dosimetry
For clinical dosimetry, the licensee shall ensure
that the following items are determined and
documented:
documented

 (a) in radiological examinations, the
     representative values for typical sized adult
     patients of entrance surface doses, dose-area
     products, dose rates and exposure times, or
                                          times
     organ doses;
            doses



                                              52. (1)(a)
Quality assurance for medical
exposure
53. (1) The licensee shall establish a comprehensive QAP
for medical exposure with the participation of appropriate
qualified experts in the relevant fields as specified by the
appropriate authority.
  (2) The quality assurance programmes for medical
      exposure shall include:
  (a) the measurement of the physical parameters of the irradiating
      apparatus, imaging devices and irradiation installations at the
      time of commissioning and periodically after the commissioning;
  (b) verification of the appropriate physical and clinical factors used
      in patient diagnosis or treatment;
  (c) written records of relevant procedures and results;
  (d) verification of the appropriate calibration and conditions of
      operation of dosimetry and monitoring equipment
Guidance levels for Medical
Exposure
• As a guide by approved registered medical
   practitioners, in order that :
  (a) corrective action is taken as necessary if doses or
      activities fall substantially below the guidance
      levels and the exposures do not provide useful
      diagnostic information and do not yield the
      expected medical benefit to patients; and
  (b) review is considered if doses or activities exceed
      the guidance levels as an input to ensuring
      optimized protection of patients and maintaining
      appropriate levels of good practice.
                                                 Reg. 54 (1)
Tables I of the Sixth Schedule
          GUIDANCE LEVELS FOR DIAGNOSTIC RADIOLOGICAL PROCEDURES
Guidance levels of dose for diagnostic radiography for a typical adult patient

Examination                                    Projection             ESD per radiograph *
                                                                           (mGy)
Lumbar spine                                               AP                     10
                                                           LAT                    30
                                                           LSJ                    40
Abdomen, intravenous, urography                            AP                     10
and cholecystography
Pelvis                                                     AP                     10
Hip joint                                                  AP                     10
Chest                                                      PA                     0.4
                                                           LAT                    1.5
Thoracic spine                                             AP                     7
                                                           LAT                    20
Dental                                                     Periapical             7
                                                           AP                     5
Skull                                                      PA                     5
                                                           LAT                    3
In air with back-scatter. These values are for conventional film screen combination in the relative speed of
200. For high speed film screen combinations (400-600), the values should be reduced by a factor of 2 to
Tables II of the Sixth Schedule
Dose guidance levels for computed tomography for a
                typical adult patient


Examination               Multiple scan average dose
                                   (mGy)

Head                             50
Lumbar spine                     35
Abdomen                          25
European Guidance Levels for Computed
Tomography for a Typical Adult Patient and Children
                                           Reference levels
                                     CTDIw (mGy)      DLP (mGycm)
 Adults (typical value)
  Chest                                  30               650
  Chest high resolution                  35               280
  Abdomen                                35               780
  Pelvis                                 35               570
  Head                                   60               1050
 Children age <15y (typical value)
  Chest                                  30               600
  Chest high resolution                  50                   100
  Abdomen                                30               800
  Pelvis                                 30               500
  Head                                   70               750
Investigation, notification and
reporting of accidental medical
exposure

(1) The licensee shall notify the appropriate
    authority of all accidental medical
    exposures within 24 hours after the
    occurrence of such accidental medical
    exposures.




                                          Reg. 57 (1)
Cont…
(2) The licensee shall immediately investigate
the following accidental medical exposures:
(b) diagnostic exposure substantially greater
    than intended or resulting in doses
    repeatedly and substantially exceeding the
    established guidance level as specified in
    the Sixth Schedule;
(c) any equipment failure, accident, error, mishap
    or other unusual occurrence with the potential
    for causing a patient exposure significantly
    different from that which is intended.
                                           Reg. 57 (2)
Cont…
(3) The licensee shall, with respect to any
   investigation carried out under subregulation (2)
(a) calculate or estimate the doses received and their
   distribution within the patient;
(b) indicate the corrective measures required to prevent
   recurrence of such an incident;
(c) implement all the corrective measures that are under
   his responsibility;
(d) submit a written report within 30 days after the
   completion of the investigation stating the cause of the
   accidental medical exposure to the appropriate
   authority, and
    authority
(e) inform the patient and the approved registered medical
   practitioner about the incident.
Records
58. (1) The licensee shall keep for a period as
may be specified by the appropriate authority
and make available, when required, the
following records:

(a) in diagnostic radiology, necessary
    information to allow retrospective dose
    assessment, including the number of
    exposures and the duration of fluoroscopic
    examinations;
Prevention of accidents
The licensee shall make suitable arrangements to prevent any
accident that could reasonably be foreseen for any radiation source
and to limit the consequences of any accident that occurs.
 (a) adequate procedures are established for the control of the radiation
     source and of any potential accident that is reasonably
     foreseeable;
 (b) the system, components and equipment which are important for
     safety are inspected and tested for any degradation that could lead
     to abnormal conditions or inadequate performance;
 (c) appropriate maintenance, inspection and testing are carried out
     without undue occupational exposure;
 (d) appropriate automatic systems for safely shutting off or reducing
     radiation output from the radiation source when the operating
     conditions exceed the operating ranges are provided; and
 (e) provide a system which can detect and respond immediately to
     abnormal operating conditions that can significantly affect the
     protection or safety and to allow for timely corrective action to be
     taken, is provided.                                             Reg. 67
Notification of theft, loss or
sabotage
The licensee shall, upon discovering any theft, loss or
sabotage of any radiation source in his possession or
under his control :
 (a) notify the appropriate authority of such theft, loss
     or sabotage within 24 hours after discovering the
     theft, loss or sabotage; and
 (b) submit a complete report of the theft, loss or
     sabotage in writing within 30 days after the
     notification to the appropriate authority.


                                                       71. (1)
Notification of theft, loss or sabotage…
cont
The report shall contain :
(a) where appropriate, a description of the radiation source, including
    its kind, quantity and its chemical and physical forms;
(b) a description of the circumstances under which the theft, loss or
    sabotage occurred;
(c) a statement of the location or probable location of the radiation
    source;
(d) the possible radiation exposure to individuals, circumstances under
    which the exposures may occur, and the extent of potential hazard
    to members of the public;
(e) the actions which have been taken, or will be taken, to recover the
    radiation source;
(f) the procedures or measures which have been or will be adopted to
    prevent a recurrence of the theft, loss or sabotage of the radiation
    source; and
(g) any other information as the licensee deems necessary.
Submission of Documents
The appropriate authority may require the licensee to submit any or
all of the followings:
(a)   a report on area monitoring;
(b)   a report on environmental monitoring;
(c)   a report on radioactive discharge;
(d)   a report on personnel monitoring;
(e)   a report on accidental exposures and emergency exposures;
(f)   a report by approved registered medical practitioners;
(g)   operational procedures, instructions and manuals;
(h)   emergency plans and procedures;
(i)   training programmes;
(j)   physical protection measures; and
(k)   other reports and records as the appropriate authority deems
      necessary.
                                                                Reg. 77
PART X - GENERAL




Transitional provisions
A person who holds a licence issued under
the Act in relation to activities involving
ionizing radiation that is still in force at the
date of commencement of these Regulations
shall, within 2 years from the date of
commencement, comply with the
requirements under these Regulations.


                                             Reg. 79
Draft Radiation Protection (Medical,
  dental and veterinary Usage of
   Radiation) Regulations 20__

- More comprehensive regulation to control
  the use of ionizing radiation in medicine
  under the purview of MoH
  - the draft regulations for medical usage were
     prepared with IAEA technical assistance
  - Approved by Radiological Advisory Committee
    (RAC)
  - To be reviewed & discussed in JKK of MoH
Cont..

Contents
    Establishment of Radiation Protection Programme
    Radiation Protection Committee
    Role of Radiation Protection Officer
    Implementation of Quality Assurance Programme (QAP)
    Radiation Protection Survey
    Notification, Reports and Records of Reportable Events
    Additional requirements for general radiography,
    fluoroscopy, CT, mammography, dental radiology &
    veterinary (RADIOLOGY)
    Additional requirements for Radiotherapy
    Additional requirements for Nuclear Medicine
In the numbers
(5)                238
                 radiografi am
Part IV


  Regulatory & Licensing
Requirements in Diagnostic
        Radiology
Circular to Private Hospital/GP’s
      Clinics Issued on 21 Oct 1999
Requirements                                 Effective date
• Only Trained Personnel (GP’s Clinic)   –      1.1.2000
• At least 1 qualified radiographer      –      1.1.2000
  (Private Hosp)
  Training of New Applicants             –      1.1.2000
  Implementation of QAP:
  - QC of Equipment, Processor           –      1.1.2000
     & Associated Facilities
   - CME Annually                        –      1.1.2002
   - Film Reject Analysis                –      1.1.2002
   - Audit of X-Ray Radiographs          –      1.1.2002
     (GP Clinic only)
Circular to TKPK (Medical) and
  TKPK (Public Health) – 15.1.2001

All plans for facilities under Act
304 to be submitted and approved
by Radiation Health and Safety
Branch, Engineering Services
Division before commencement of
installation/renovation
All related equipment and facilities to be
tested, commissioned and verified to conform
to safety and performance standards before
clinical use
Cont…



   Implementation of QAP
   • Quality control (QC) of equipment,
     processors and associated facilities
   • Monitoring and analysis of film
     reject rate
   • Continuous Professional Education
     (CME)
Procedures To Apply For A License
(Private) or Getting Approval (Public)

                  STEP 1

       Requirements to BUY &
       STOR Irradiating Apparatus



                  STEP 2

          Requirements to USE
          Irradiating Apparatus
Step 1
 Documents required to apply for BUY & STORE
            Irradiating Apparatus

 Application form (private) or letter of intent
  (public)
 Application/Licence fee (private)
 Copy of current APC
      The address of practice stated in APC shall be the same
      as the address of where apparatus is to be stored or used

 Layout plan of the premises
 Detailed plan of the room where the
  apparatus will be located
 Description of irradiating apparatus
 FACILITIES
  Layout plan of premises

    Layout plan of premises shall indicate
      - Location of the x-ray room, darkroom &
        occupied area in the premise
      - All plan shall be in technical drawings &
        the scale shall be in metric (S.I) unit

        Note:
        No licence will be issued for X-ray practice in
        free standing laboratory where there is no
        doctor practicing in the premise
 FACILITIES
   Detailed Plan of X-ray Room & Dark Room

  Detailed Plan of X-ray room shall clearly
  specify the following :

    i.   Dimension of the x-ray room
    ii. Material used and thickness of the wall, ceiling
        and floor
    iii. Position, size & material used for the windows,
         doors and other openings
    iv. Position of the apparatus in the x-ray room
    v. Position of the operating console/control area
    vi. Warning light/sign at the door of the room
 X-RAY ROOM- Layout and Dimension


               Type of Equipment
                                   General X-Ray *       Fluoroscopy
  Plan Spec.
  Dimension of the room              3.0 m x 4.0m         6.0 m x 4.0m
  Thickness of Shielding at the      2.0mm Pb eq          2.0mm Pb eq
  Doors and Walls
  Dimension & Thickness of Lead      1.2m x 1.2m x       1.2m x 1.2m x
  at the Chest Wall                  2.0mm Pb eq         2.0mm Pb eq
  Dimension & Thickness of Lead      35cm x 30cm x       100cm x 50cm x
  Glass Observation Window           2.0mm Pb eq          2.0mm Pb eq
  Dimension & Thickness of Lead      1.2m x 2.5mx        1.2m x 2.5mx
  at the Floor (upper floor)           2.0mm Pb            2.0mm Pb

        * Control panel outside with examination table
                                                                  Cont….
 X-RAY ROOM- Layout and Dimension


                Type of Equipment
                                    Mammography      CT Scanner
  Plan Spec
  Dimension of the room              2.5 m x 3.0m    5.5 m x 4.0m
  Thickness of Shielding at the      1.0mm Pb eq     2.0mm Pb eq
  Doors and Walls
  Dimension & Thickness of Lead          NA              NA
  at the Chest Wall
  Dimension & Thickness of Lead           NA        100cm x 50cm x
  Glass Observation Window                           2.0mm Pb eq
  Dimension & Thickness of Lead          NA         1.2m x 2.5mx
  at the Floor (upper floor)                           2.0mm

       NA - Not applicable
                                                              Cont….
 X-RAY ROOM- Warning Signs


  - All entrances to x-ray
    rooms shall be marked                           R

    with a warning sign
  - Consist of a three-
    blade design using the
    radiation caution
    colours, that is black
    for the design and
    yellow for the
    background.
                                            1.5 R


                                              
    R is the radius of theis correct ?
              Which one inner                5R
    circle and 5R is not less than
    7.5 cm
                                         MS 838:1985    Cont….
New Radiation Symbol ????




New Symbol launched to warn public about radiation
dangers - supplementary symbol aims to help reduce
needless deaths and injuries, IAEA – 15 February 2007
 X-RAY ROOM- Warning Light


    All entrances to x-ray rooms
    shall have a light that is
    illuminated prior to exposure
    or when fluoroscopy is in
    progress
    The warning light should be
    red in colour (yellow or amber
    may also be used)
    MS 838:1985
                                     Cont….
 DARKROOM- Dimension & Location


    Minimum Dimension of = 1.5m x 2.0m
    Darkroom

    Location of darkroom
    shall not be in the
    direction of the
    useful beam.
    MS838:2007
Step 2

  Requirements to STORE & USE Irradiating
                Apparatus

• Personnel &          Licensee/Org Yg Bertanggungjawab
  Training             Supervisor
                       RPO
                       Operators

  • Facility               X-ray Room
                           Dark room

     • Equipment             X-ray Machine
                             Processor/cassette/Viewer, etc

        • Procedures            Local rules, etc
Requirements to STORE & USE Irradiating
                  Apparatus


    Licensee/Org Yg Bertanggungjawab :
     GP clinics/Non X-ray Sp. Clinics/Health
     Clinics
        Registered Medical Doctor
        undergo 40 credit hours training program (new
        applicant)

     Hospital/Radiological Clinic
        Registered Med. Doc/Pengarah@ Radiologist
        Attend continuous professional education (CME)
        program
Requirements to STORE & USE Irradiating
                Apparatus

 Supervisor :
   GP clinics/Non X-ray Sp. Clinics/Health
   Clinics
      Registered Medical Doctor
      Attend yearly continuous professional education
      (CME) program

   Hospital/Radiological Clinic
      Radiologist
      Attend yearly continuous professional education
      (CME) program
Requirements to STORE & USE Irradiating
                  Apparatus


    Radiation Protection Officer (RPO) :
     GP clinic/Non X-ray Specialist Clinic
        Registered Medical Doctor or radiographer
        Attend yearly continuous professional education
        (CME) program

     Hospital/Radiological Clinic
        Med. Physicist/Radiologist/radiographer
        Attend yearly continuous professional education
        (CME) program
Requirements to STORE & USE Irradiating
                  Apparatus


    X-ray Operator :
    GP clinic/Non X-ray Sp. Clinic

       undergo 50 credit hours training program
       (new operator);
       Attend continuous professional education
       (CME) program yearly
       Having a personnel monitoring devices
       do a medical surveillance once in 3 years
Training Syllabus For New Licensees &
New Operators

Doctors applying for new licences and newly employed
operators are required to undergo the following courses
before they are permitted to use the x-ray equipment

 Mod. 1: Radiation Safety Awareness             9 cr. hrs
 Mod. 2: X-ray Equipment and Associated        10 cr. hrs
         facilities
 Mod. 3: Clinical Practices                    31 cr. hrs
 Mod. 4: Radiographic Techniques and QAP       21 cr. hrs
 TOTAL : (Module 1, 2 & 3 – for operators)    50 cr. hrs
         (Module 1, 2 & 4 – for doctors)      40 cr. hrs
Existing X-ray Operator*
1. X-ray operators currently employed in the clinics
   and have been trained in the Orientation
   Programme conducted by the College of General
   Practitioners X-Ray Society of Malaysia or ANM
2. Workers trained in programme approved by the
   Licensing Authority – the training syllabus and
   facilities would be vetted before approval is given
3. Medical practitioners


    * Subjected to do chest & extremities only
Requirements to STORE & USE Irradiating
               Apparatus


Hospital/Radiology clinic
   Employment of at Least 1 Radiographer
   Mammography procedures shall be
   performed by a qualified female radiographer
   trained in mammography
   Attend continuous professional education
   (CME) program yearly
   Having a personnel monitoring devices
   Do a medical surveillance once in 3 years
Medical
                                             Surveillance
                                             (Buku LPTA/BM/5)



Nota: Pemeriksaan x-ray dada hanya perlu     Question:
dibuat utk jangkamasa lima (5) tahun
sekali; atau apabila difikirkan perlu oleh   Do you require to
pengamal perubatan berdaftar yang            do chest x-ray for
diluluskan.                                  medical check-up
                                             every time?
   CME All personnel

    All personnel/operators (include licensees) are
    required to attend CME programme to update their
    knowledge in order to keep abreast of the current
    practices in radiology annually.
    The training programme may include one of the
    following :
     • Radiation protection pertaining to the use of x-ray
        equipment
     • Radiographic techniques
     • Image quality criteria and requirements
     • X-ray reporting
     • Management of QAP
     • Film processing
     • Update in radiology imaging
   CME
    All personnel

    The above may be
    achieved :

     By attending courses organized by other
      agencies/ organizations/ societies/ ect
     Peer reviewed educational programmes/
      distance learning programmes available
      either on the internet or through posts
 FACILITIES & X-RAY EQUIPMENT
  Safety and Performance Standard

     QC of Equipment and Associated Facilities:

      Tested & certified by consultant medical
       physicist approved by MoH – Class H
       (certification)
      Submit certificate with summary report
       and full report to MoH
 FACILITIES & X-RAY EQUIPMENT
  Safety and Performance Standard

   Facility/
                    Parameter               Optimum Achievable Std
  Equipment
                     Machine
  Irradiating
                   performance           As specified in the Standard 
  Apparatus
                    parameter
                                    Exp. rate at every occupied
                                    outside the x-ray room and at the
  X-Ray Room    Scattered Radiation position normally occupied by the
                                    operator at the control area shall
                                    not exceed 10mR in one week
                Condition of the
  Dark Room                            No light leakage
                dark room
                                       No light leakage
                Condition of all the
  Cassettes                            Film and screen should be in good
                cassettes              contact
 ADDITIONAL REQUIREMENTS
  Monitoring & analysis of film reject rate
   Monitoring and Analysis of Film Reject Rate
    A report of monitoring and analysis of film
    reject rate shall be submitted every year. It
    should include the following:
     i. Monitoring Period
     ii. No. of film used
     iii. No. of film rejected and percentage
     •   Corrective action taken when reject rate > 10%
 ADDITIONAL REQUIREMENTS
  Audit of X-Ray Radiographs

  Audit of X-ray Radiographs*
    i) Film Audit by Radiologist
   10 x-ray radiographs selected randomly from GP’s clinics
   will be audited by radiologist based on established
   criteria and standard under circular issued on
   21-10-1999.
   For each radiograph a minimum score of 7 is required to
   pass the audit. At least, 7 out of 10 films audited should
   meet the minimum score of 7 before they are considered
   to have pass the overall audit

      * For GP’s Clinic/Sp. Clinic only
 ADDITIONAL REQUIREMENTS
  Audit of X-Ray Radiographs




    ii) Letter from Fomema (for Fomema panel’s
        clinics)
    Letter from Fomema to confirm that clinics are
    participating regularly in the X-ray Quality Control
    Programme of Fomema and x-ray films taken are
    satisfactory and adhere to the SOP
Question

Does ‘radiation leave’ cover
under Act 304 or subsidiary
regulations ?

Answer

NO
Perintah Am Bab C – 47 Cuti tugas khas perubatan
(14 hari) 
SUMMARY
Documents required to BUY/ STORE
Irradiating Apparatus
 Documents Required                       Private   Public
 Completed Borang LPTA/BP/3 or letter
 of intent                                           
 Application fee & License fees                       
                                            
 Copy of current APC                                 
 Layout plan of the premises                         
 Detailed plan of the X-ray room
 where the apparatus will be located                 
 Catalogue/detailed of the apparatus to
 be licensed & copy of supplier license              
Cont..

Documents required to STORE/USE
Irradiating Apparatus

 Documents Required                      Private   Public
 QC of Equipment Certificates                       
 Licensee/supervisor/RPO – CME                       
                                           
 Operators – Med. check up/Film badge/
 CME                                                
 FRRA Report                                        
 Audit Film Report *                                
 * GP Clinics
Summary

        OVERALL



                Protection &
Image Quality
                   Safety
Thank You For Your
    Attention
PERINTAH-PERINTAH AM
BAB C: CUTI
47 Cuti Khas Perubatan
Kelayakan :

(i) Pegawai yang menjalankan tugas x-ray sepenuh masa
    dan terdedah kepada pancaran x-ray
(ii) Pegawai di pusat-pusat perubatan tertentu di mana
     jenis- jenis tugas yang dijalankan adalah atau tidak
     digemari. Pusat-pusat perubatan ini hendaklah seperti
     yang diluluskan oleh Ketua Pengarah Perkhidmatan
     Awam dari masa ke semasa

    TEMPOH : 14 hari setahun. Tidak boleh dikumpul dan
             hendaklah diambil dalam tahun yang ianya
             diperolehi

                                                             Back
 X-RAY EQUIPMENT
  Safety and Performance Standard (General X-ray)

                              OPTIMUM ACHIEVABLE       REMEDIAL   SUSPENSION
         PARAMETERS
                                   STANDARD             LEVEL        LEVEL

 1. X-Ray Generator
 ii) Accuracy of kVp          Max. Deviation ± 5%       >5%       > 20 %
                              or ± 5kV whichever is
                              smaller.

 ii) Accuracy exposure time   Maximum Deviation :
     a) for time ≥ 0.1sec      ± 10%                   > 10 %     > 25 %
     b) for time < 0.1 sec     ± 20%                   > 20 %     > 30 %


                              Maximum deviation ±     > 10 % or   >30 % or
 iii) Exposure                                                    baseline
                              10%                     baseline
      reproducibility                                             >50 %
                                                        > 20 %
 iv) Exposure linearity       Maximum deviation :
                              10%                     > 10 % or   > 30 % or
                                                      baseline    baseline
                                                       >20 %      >50 %
 X-RAY EQUIPMENT
  Safety and Performance Standard (General X-ray)

                             OPTIMUM ACHIEVABLE       REMEDIAL   SUSPENSION
            PARAMETERS
                                  STANDARD             LEVEL        LEVEL

 2. X-Ray Beam Limitation
 ii) Beam Collimation        Max. misalignment 1
                                                  o          o         o
                                                        >1          >3
                             of SID on any side

                                            o               o          o
 ii) Beam perpendicularity       Less than 2           >2           >3

 3. X-Ray Beam Filtration           mm Al             mm Al
 Below 50 kVp         30             0.3              < 0.3
                      40             0.4              < 0.4
  50 to 70           50              1.2               < 1.2
                     60              1.3               < 1.3
                     70              1.5               < 1.5
     > 70            80              2.3               < 2.3
                    100              2.7               < 2.7
                    130              3.5               < 3.5

                                                                     Cont….
 X-RAY EQUIPMENT
  Safety and Performance Standard (General X-ray)


                                      OPTIMUM
                                                        REMEDIAL    SUSPENSION
          PARAMETERS                 ACHIEVABLE
                                                         LEVEL         LEVEL
                                      STANDARD

 4. Image Quality
    i) Resolution                   Please specify     Baseline ±
                                     the resolution      2 group
    ii) Contrast                   and contrast and
                                                                        -


                                    attach test film


 5. Leakage Radiation
 Exposure from the leakage         0.1mGy (10mR)       > 0.1mGy     > 1.0 mGy
 radiation at 1m from the x-ray                         (10mR)      (100 mR)
 tube in an hour at every rating
 specified by the manufacturer.




                                                                        [back]

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Act and regulatory requirements hotel selesa 9 jun2012

  • 1. ACT 304 AND RELATED REGULATORY REQUIREMENTS IN DIAGNOSTIC RADIOLOGY Muhammad Khalis Bin Abdul Karim Radiation Health and Safety Unit Johor State Health Department Ministry of Health Malaysia
  • 2. Contents Background Atomic Energy Licensing Act 1984 (Act 304) Subsidiary regulations under Act 304 Regulatory and Licensing Requirements in Diagnostic Radiology
  • 4. Legislation Hierarchy 1 Act Regulations Legally 2 Bound Circulars/ Standards 3 & Code* Local Rules, 4 Guidelines, Voluntary Instructions Manual * Not regulatory by itself but becomes regulatory if linked to Regulations/Acts
  • 5. In the numbers (1) 6,570 radas
  • 6. Malaysian Legislation Radioactive Substance Act 1968 - First legislation regulating the use of ionising radiation. - MOH control the use of ionising radiation for medical and non-medical Atomic Energy Licensing Act 1984 (Act 304) - Replaces and supersedes Radioactive Substance Act 1968. - Act under MOSTI
  • 7. Cont.. • Act 304 was gazetted under the purview of Ministry of Science, Technology and Innovation Malaysia (MOSTI). • The Director-General of Health where the activity to be licensed under this Act is in respect of the use of ionizing radiation for medical purpose as determined in Section 15 (2) Act 304. • RHSS, MOH is entrusted as the secretariat for the D-G of Health, in all activities that related to the use of ionising radiation for medical purposes.
  • 8. Regulatory Authority Atomic Energy Licensing Board (AELB) (Regulatory Authority) Authority Medical Non-Medical Ministry of Health Ministry of Science, Tech and Malaysia Innovation (MOSTI) Director General of Health Executive Secretary to the (Regulatory Authority) Authority Board Secretariat: Secretariat : Radiation Health & Safety Section AELB (Dept) (RHSS), MoH
  • 9. Malaysian Legislation Main Act Atomic Energy Licensing Act 1984 (Act 304) Subsidiary Regulations  Radiation Protection (Licensing) Regulations 1986  Atomic Energy Licensing (Basic Safety Radiation Protection (Basic Safety Standard) Radiation Protection) Regulations 2010 Regulations 1988  Radiation Protection (Transports) Regulations 1989
  • 10. Malaysian Legislation Guidelines/Circulars  Malaysian Standards (MS 838) : Code of Practice For Radiation Protection (Medical X-Ray Diagnosis) - 1985 (1st Revision, 2007)  Circular on Employment of Trained X-Ray Operators By Private General Practitioners - 1993  Guidelines To Obtain Class C License Under the Atomic Energy Licensing Act 1984 - 1994  Guidelines For Medical Diagnostic Procedures Using X-ray For Women of Childbearing Potential - 1998
  • 11. Malaysian Legislation Continue..  Circulars on Licensing Requirements Under Act 304 For Specialized Diagnostic Radiology Services Provided by Private Hospitals/ Radiology Clinics – 1999  Circulars on Licensing Requirements Under Act 304 For Specialised Diagnostic Radiology Services Provided by GP Clinics - 1999  Circulars to TKPK(Medical), TKPK(Public Health) & Pengarah Perancang & Pembangunan – 2001  Guidelines On The Use of Mobile X-ray Machines - 2005
  • 12. Part II Atomic Energy Licensing Act (Act 304)
  • 13. Atomic Energy Licensing Act 1984 Contents Atomic Energy Licensing Board, functions, powers • Control and licensing • Cancellation, Suspension and Renewal of Licenses • Health and Safety • Disposal of Radioactive Waste • Power of seizure and Arrest, Offences and Forfeiture • Liability for Nuclear Damage
  • 14. Act 304 Appropriate Authority a) The Director-General of Health where the activity to be licensed or licensed under this Act is in respect of a medical purpose b) The Board where the activity to be licensed or licensed under this Act is in respect of a purpose other than a medical purpose Sec 2 of Atomic Energy Licensing Act 1984
  • 15. Act 304 Control and licensing 12.(1) Without prejudice to the requirements of any other law, no person shall : a) site, construct or operate a nuclear installation b) deal in, possess or dispose of any radioactive material, nuclear material, prescribed substance or irradiating apparatus unless he is the holder of a valid license
  • 16. Act 304 12.(3) A licence for using any any radioactive material, nuclear material, prescribed substance or irradiating apparatus for diagnostic or therapeutic purposes may be issued ONLY to a registered medical practitioner, registered veterinary surgeon, radiologist, radiotherapist or registered dentist
  • 17. Act 304 Condition of Licenses 17(1) Licenses issued under this Act shall be subjected to such conditions as may, be imposed by the appropriate authority which may in respect of the conditions imposed by it, add to, vary or revoke such conditions at any time.
  • 18. Act 304 Cancellation, Suspension and Renewal of Licenses 22(1) The appropriate authority may at any time under any of the following circumstances in its discretion cancel, or suspend any license ; a) Where the licensee has committed an offence under this Act b) Where the licensee has committed a breach of any of the conditions of the license c) Where the licensee ceases to work or operate the nuclear installation in respect of which the license was issued d) Where in the opinion of the appropriate authority it would be in the public interest so to do
  • 19. In the numbers (2) 660 radas penyinaran
  • 20. In the numbers (3) 279 premis swasta
  • 21. Act 304 Health and Safety 25 (1) Every licensee shall comply with all such directives as the appropriate authority may issue…, including : a) Conditions of exposure b) Dose limitation c) Occupation exposure d) Medical exposure e) Exposure of members of the public f) Accidental exposure g) Emergency exposure
  • 22. Act 304 25 (2) If the appropriate authority has reasonable cause to believe that any workers has been or likely to be exposed …, licensee shall : a) provide and require such worker to wear approved personnel monitoring devices b) keep records of dose and type of ionizing radiation c) install or use monitoring devices in work places to record the amount of ionizing radiation present d) provide medical examination for such worker
  • 23. Act 304 Disposal of Radioactive Waste 26 (1) No person shall dispose of or cause to be disposed any radioactive waste without the prior authorization in writing of the appropriate authority
  • 24. Act 304 Powers of Seizure and Arrest, Offences and Forfeiture 33 (1) & 34 (1) Senior Public Officer authorize to, with or without warrant : a) Enter the premises, site, nuclear installation or conveyance and there to search and seize such radioactive material, nuclear material, prescribed substance, irradiating apparatus, book or document; b) Arrest any person being in or on the premises, site, nuclear installation or conveyance in whose possession or under whose control such radioactive material, nuclear material, prescribed substance, irradiating apparatus, book or document is found;
  • 25. Act 304 33(2) Senior Public Officer may if necessary, with or without assistance:- • Break open any door or window or part of the premises, site, nuclear installation or conveyance and there to have ingress thereinto; • Forcibly enter the the premises, site, nuclear installation or conveyance • Remove by force any obstruction to entry, search, seizure and removal as he is empowered to effect d) Detain every person found in or on the premises, site, nuclear installation or conveyance until the premises, site, nuclear installation or conveyance has been searched
  • 26. Act 304 38(1) Any radioactive material, nuclear material, prescribed substance, irradiating apparatus or radioactive waste in respect of which an offence under this Act is committed, or any book, document or conveyance connected with such offence is liable to forfeiture
  • 27. Act 304 Offences 39 – Specific offences [(a) – (i)] under this Section is, on conviction, liable to imprisonment for a term not exceeding 5 YEARS or a fine not exceeding RM10,000 or BOTH 40(2) Any person who commits an offence under this Act is liable to imprisonment for a term not exceeding 10 YEARS or a fine not exceeding RM100,000 or BOTH
  • 28. Part III Subsidiary Regulations under Act 304  Radiation Protection (Licensing) Regulations 1986  Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations 2010  Draft Radiation Protection (Medical, Dental and Veterinary Usage of Radiation) Regulations 201__
  • 29. Radiation Protection (Licensing) Regulations 1986 Contents  Classification of licenses  General Conditions for Obtaining a License  Application for, Amendment and Renewal of License  License fees - Review fees and application forms – one form for all type of application, etc – still in JKK of LPTA
  • 30. Classification of Licenses A license to manufacture, trade in, produce, process, Class A purchase, own, possess, use, transfer, handle, sell or store radioactive material A license to manufacture, trade in, ..… or store nuclear Class B material A license to manufacture, trade in, ….. or store irradiating Class C apparatus A license to transport radioactive material, nuclear material, Class D prescribed substances or their waste A license to export or import radioactive material, nuclear Class E material, prescribed substances, irradiating apparatus or their waste
  • 31. Cont.. A license to site, to construct or to operate a nuclear Class F installation A license to • dispose of radioactive material, nuclear Class G materials, prescribed substances or their wastes • store of radioactive material, nuclear materials, prescribed substances or their wastes prior to their disposal • Decommission a milling installation, nuclear installation, waste treatment facility, irradiating apparatus or sealed sources apparatus A license to control of activities not covered by classes Class H A to G
  • 32. General Conditions For Obtaining a Licenses 12 (a) The applicant shall employ a person or persons having the necessary knowledge, skill and training to ensure that the activities sought to be licensed are carried out in such manner as to protect the health of workers and members of the public (b) The applicant’s proposed equipment, facilities and procedures shall be adequate to protect the health of workers and member of the public and to minimize danger to life, property and the environment
  • 33. License & Application Fees Category/Type of Irradiating License fee per year in RM Apparatus Dental X-ray units, mobile & RM100 for the first apparatus 1 fixed medical x-ray units, mobile veterinary X-ray units RM20 for every additional apparatus X-ray therapy units not RM300 for the first apparatus 2 operable above 500kVp RM60 for every additional apparatus CT Scanner units, RM1000 for the first apparatus 3 Accelerators, X-ray therapy units operable above 500kVp RM200 for every additional apparatus Application Fee RM15 Reg 15 of Rad. Protec (Licensing) Regulations 1986
  • 34. Cont.. Category of Sealed Source License fee per year in RM 1 RM100 for the first source Any sealed source with activity not greater RM20 for every additional source than 40MBq 2 RM200 for the first source Radiation gauges and other sealed RM40 for every additional source sources not specified in this Schedule 3 RM300 for the first source Medical therapy sources with activity not RM60 for every additional source greater than 400MBq, etc 4 Medical therapy sources with activity RM1000 for the first source greater than 400MBq, irradiation cell for RM200 for every additional source sterilization purposes, etc Reg 15 of Rad. Protec (Licensing) Regulations 1986
  • 35. In the numbers (4) 21 CT Scan
  • 36. Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations 2010 15 February 2010
  • 37. OLD NEW Radiation Atomic Energy Protection (Basic VS Licensing (Basic Safety Standard) Safety Radiation Regulations 1988 Protection) Regulations 2010  Based on ICRP 26,  Based on ICRP 60, 1977 1990  56 provisions  80 provisions  Medical Exposure – 5  More provisions on provisions Medical Exposure – 18 provisions
  • 38. Interpretation “medical exposure” means the exposure exposure incurred by : (a) a patient as part of his medical or dental investigative or diagnostic procedures or treatment; (b) a person who knowingly assists in the support and comfort of patients, other than a person who is occupationally exposed; or (c) a volunteer in a medical research programme that involves radiation exposure; Reg. 3
  • 39. Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations 2010 ARRANGEMENT OF REGULATIONS PART I - PRELIMINARY PART II - SYSTEM OF RADIATION PROTECTION PART III - OCCUPATIONAL EXPOSURE PART IV - MEDICAL EXPOSURE Specific provisions in diagnostic radiology • Requirements for irradiating apparatus and equipment using sealed sources for diagnostic radiology • Operational consideration for diagnostic exposure • Clinical dosimetry • Quality assurance for medical exposure • Guidance levels • Investigation, notification and reporting of accidental medical exposure
  • 40. Cont.. ARRANGEMENT OF REGULATIONS PART V - PUBLIC EXPOSURE PART VI - POTENTIAL EXPOSURE AND SAFETY OF RADIATION SOURCES PART VII - INTERVENTION PART VIII - SUBMISSION OF DOCUMENTS PART IX - CESSATION OF OPERATIONS, DECOMMISSIONING OR ABANDONMENT OF LICENSED FACILITIES PART X - GENERAL
  • 41. PART I - PRELIMINARY Working Area Classification of Clean Areas, Supervised Areas Working Areas : and Controlled Areas “clean area” - an area where the annual dose received by a area worker is not likely to exceed the dose limit for a member of the public; “controlled area” - area in which specific protection measures and area safety provisions are required for controlling normal exposures or preventing the spread of contamination during normal working conditions, and preventing or limiting the extent of potential exposures; “supervised area” - an area for which occupational exposure area conditions are kept under review even though specific protective measures and safety provisions are not normally needed; Reg. 3
  • 42. PART III - OCCUPATIONAL EXPOSURE Classification of Working Area Supervised Areas and Controlled Areas have to clearly demarcated and appropriate legible notices and warning signs bearing the radiation symbol are posted conspicuously in strategic places. Question Where is the area considered as controlled area in a diagnostic imaging department ??
  • 43. PART II - SYSTEM OF RADIATION PROTECTION Dose Limit for Workers & Member of Public Whole Body Exposure Dose Limit (mSv/year) BSS 1988 BSS 2010 Public 1 1 Radiation Workers 50 20* Foetus 10 1 * The maximum effective dose on the worker averaged over a period of 5 consecutive years shall not exceed 20mSv Reg. 8 & 9
  • 44. Question What is the patient dose limit ? A: 1 mSv/year Public B: 20 mSv/year Radiation workers (new BSS Regulations – 2010) C: 50 mSv/year D: 150 mSv/year Radiation workers (old BSS Regulations 1988) ANS: NO LIMIT Lens of the eyes
  • 45. Personnel Monitoring (1) The licensee shall be responsible for arranging the assessment of the occupational exposure of workers (2) The licensee shall carry out personnel monitoring for all workers who normally work in a controlled area, and workers who occasionally work in a controlled area but may receive significant occupational exposure. (3) Personnel monitoring shall not be required for any worker who normally works in a supervised area, or area who enters a controlled area only occasionally, but the occupational exposure of the worker shall be assessed on the basis of the results of work place monitoring Reg. 22
  • 46. PART IV - MEDICAL EXPOSURE Responsibilities of licensee or employer To ensure that : (a) no patient is administered with a diagnostic or therapeutic medical exposure unless the exposure is prescribed by an approved registered medical practitioner; (b) an approved registered medical practitioner is assigned with the primary task and obligation of ensuring overall patient protection and safety in the prescription of, and during the delivery of, diagnostic or therapeutic medical exposure to the patient; Reg. 41
  • 47. Cont… (c) an appropriate healthcare professional who is adequately trained to discharge assigned tasks to the patients in the conduct of the diagnostic or therapeutic procedures that the approved registered medical practitioner prescribes, is available; (d) for diagnostic uses of radiation, the quality assurance programme specified by the appropriate authority is conducted by or under the supervision of a qualified expert in medical physics;
  • 48. Operational consideration for diagnostic exposure (1) For diagnostic radiology practices, the licensee shall ensure: (a) the exposure of patients is at the minimum level required in order to achieve the intended diagnostic objective; (b) the relevant information from previous examinations is taken into account in order to avoid unnecessary additional examinations; and (c) the relevant guidance levels as specified in the Sixth Schedule is taken into account. Reg. 48
  • 49. Cont… The licensee shall ensure that … the diagnostic procedure chosen to produce the minimum exposure to patient is consistent with the acceptable image quality and the clinical purpose of the examination. the portable and mobile radiological equipment is used only for examinations where it is impractical or not medically acceptable to transfer patients to a stationary radiological installation, and only after proper attention has been given to the radiation protection measures that are required in its use.
  • 50. Cont… The licensee shall ensure that … any radiological examination causing exposure to the abdomen or pelvis of women who are pregnant or suspected to be pregnant is avoided, unless there are avoided strong clinical indications for such examinations. any diagnostic examination of the abdomen or pelvis of women of reproductive age is planned to deliver the minimum dose to the ovary or to any embryo or foetus that might be present. whenever feasible and appropriate, shielding of radiosensitive organs such as gonads, lens of the eye and thyroid is provided. provided
  • 51. Clinical dosimetry For clinical dosimetry, the licensee shall ensure that the following items are determined and documented: documented (a) in radiological examinations, the representative values for typical sized adult patients of entrance surface doses, dose-area products, dose rates and exposure times, or times organ doses; doses 52. (1)(a)
  • 52. Quality assurance for medical exposure 53. (1) The licensee shall establish a comprehensive QAP for medical exposure with the participation of appropriate qualified experts in the relevant fields as specified by the appropriate authority. (2) The quality assurance programmes for medical exposure shall include: (a) the measurement of the physical parameters of the irradiating apparatus, imaging devices and irradiation installations at the time of commissioning and periodically after the commissioning; (b) verification of the appropriate physical and clinical factors used in patient diagnosis or treatment; (c) written records of relevant procedures and results; (d) verification of the appropriate calibration and conditions of operation of dosimetry and monitoring equipment
  • 53. Guidance levels for Medical Exposure • As a guide by approved registered medical practitioners, in order that : (a) corrective action is taken as necessary if doses or activities fall substantially below the guidance levels and the exposures do not provide useful diagnostic information and do not yield the expected medical benefit to patients; and (b) review is considered if doses or activities exceed the guidance levels as an input to ensuring optimized protection of patients and maintaining appropriate levels of good practice. Reg. 54 (1)
  • 54. Tables I of the Sixth Schedule GUIDANCE LEVELS FOR DIAGNOSTIC RADIOLOGICAL PROCEDURES Guidance levels of dose for diagnostic radiography for a typical adult patient Examination Projection ESD per radiograph * (mGy) Lumbar spine AP 10 LAT 30 LSJ 40 Abdomen, intravenous, urography AP 10 and cholecystography Pelvis AP 10 Hip joint AP 10 Chest PA 0.4 LAT 1.5 Thoracic spine AP 7 LAT 20 Dental Periapical 7 AP 5 Skull PA 5 LAT 3 In air with back-scatter. These values are for conventional film screen combination in the relative speed of 200. For high speed film screen combinations (400-600), the values should be reduced by a factor of 2 to
  • 55. Tables II of the Sixth Schedule Dose guidance levels for computed tomography for a typical adult patient Examination Multiple scan average dose (mGy) Head 50 Lumbar spine 35 Abdomen 25
  • 56. European Guidance Levels for Computed Tomography for a Typical Adult Patient and Children Reference levels CTDIw (mGy) DLP (mGycm) Adults (typical value) Chest 30 650 Chest high resolution 35 280 Abdomen 35 780 Pelvis 35 570 Head 60 1050 Children age <15y (typical value) Chest 30 600 Chest high resolution 50 100 Abdomen 30 800 Pelvis 30 500 Head 70 750
  • 57. Investigation, notification and reporting of accidental medical exposure (1) The licensee shall notify the appropriate authority of all accidental medical exposures within 24 hours after the occurrence of such accidental medical exposures. Reg. 57 (1)
  • 58. Cont… (2) The licensee shall immediately investigate the following accidental medical exposures: (b) diagnostic exposure substantially greater than intended or resulting in doses repeatedly and substantially exceeding the established guidance level as specified in the Sixth Schedule; (c) any equipment failure, accident, error, mishap or other unusual occurrence with the potential for causing a patient exposure significantly different from that which is intended. Reg. 57 (2)
  • 59. Cont… (3) The licensee shall, with respect to any investigation carried out under subregulation (2) (a) calculate or estimate the doses received and their distribution within the patient; (b) indicate the corrective measures required to prevent recurrence of such an incident; (c) implement all the corrective measures that are under his responsibility; (d) submit a written report within 30 days after the completion of the investigation stating the cause of the accidental medical exposure to the appropriate authority, and authority (e) inform the patient and the approved registered medical practitioner about the incident.
  • 60. Records 58. (1) The licensee shall keep for a period as may be specified by the appropriate authority and make available, when required, the following records: (a) in diagnostic radiology, necessary information to allow retrospective dose assessment, including the number of exposures and the duration of fluoroscopic examinations;
  • 61. Prevention of accidents The licensee shall make suitable arrangements to prevent any accident that could reasonably be foreseen for any radiation source and to limit the consequences of any accident that occurs. (a) adequate procedures are established for the control of the radiation source and of any potential accident that is reasonably foreseeable; (b) the system, components and equipment which are important for safety are inspected and tested for any degradation that could lead to abnormal conditions or inadequate performance; (c) appropriate maintenance, inspection and testing are carried out without undue occupational exposure; (d) appropriate automatic systems for safely shutting off or reducing radiation output from the radiation source when the operating conditions exceed the operating ranges are provided; and (e) provide a system which can detect and respond immediately to abnormal operating conditions that can significantly affect the protection or safety and to allow for timely corrective action to be taken, is provided. Reg. 67
  • 62. Notification of theft, loss or sabotage The licensee shall, upon discovering any theft, loss or sabotage of any radiation source in his possession or under his control : (a) notify the appropriate authority of such theft, loss or sabotage within 24 hours after discovering the theft, loss or sabotage; and (b) submit a complete report of the theft, loss or sabotage in writing within 30 days after the notification to the appropriate authority. 71. (1)
  • 63. Notification of theft, loss or sabotage… cont The report shall contain : (a) where appropriate, a description of the radiation source, including its kind, quantity and its chemical and physical forms; (b) a description of the circumstances under which the theft, loss or sabotage occurred; (c) a statement of the location or probable location of the radiation source; (d) the possible radiation exposure to individuals, circumstances under which the exposures may occur, and the extent of potential hazard to members of the public; (e) the actions which have been taken, or will be taken, to recover the radiation source; (f) the procedures or measures which have been or will be adopted to prevent a recurrence of the theft, loss or sabotage of the radiation source; and (g) any other information as the licensee deems necessary.
  • 64. Submission of Documents The appropriate authority may require the licensee to submit any or all of the followings: (a) a report on area monitoring; (b) a report on environmental monitoring; (c) a report on radioactive discharge; (d) a report on personnel monitoring; (e) a report on accidental exposures and emergency exposures; (f) a report by approved registered medical practitioners; (g) operational procedures, instructions and manuals; (h) emergency plans and procedures; (i) training programmes; (j) physical protection measures; and (k) other reports and records as the appropriate authority deems necessary. Reg. 77
  • 65. PART X - GENERAL Transitional provisions A person who holds a licence issued under the Act in relation to activities involving ionizing radiation that is still in force at the date of commencement of these Regulations shall, within 2 years from the date of commencement, comply with the requirements under these Regulations. Reg. 79
  • 66. Draft Radiation Protection (Medical, dental and veterinary Usage of Radiation) Regulations 20__ - More comprehensive regulation to control the use of ionizing radiation in medicine under the purview of MoH - the draft regulations for medical usage were prepared with IAEA technical assistance - Approved by Radiological Advisory Committee (RAC) - To be reviewed & discussed in JKK of MoH
  • 67. Cont.. Contents Establishment of Radiation Protection Programme Radiation Protection Committee Role of Radiation Protection Officer Implementation of Quality Assurance Programme (QAP) Radiation Protection Survey Notification, Reports and Records of Reportable Events Additional requirements for general radiography, fluoroscopy, CT, mammography, dental radiology & veterinary (RADIOLOGY) Additional requirements for Radiotherapy Additional requirements for Nuclear Medicine
  • 68. In the numbers (5) 238 radiografi am
  • 69. Part IV Regulatory & Licensing Requirements in Diagnostic Radiology
  • 70. Circular to Private Hospital/GP’s Clinics Issued on 21 Oct 1999 Requirements Effective date • Only Trained Personnel (GP’s Clinic) – 1.1.2000 • At least 1 qualified radiographer – 1.1.2000 (Private Hosp) Training of New Applicants – 1.1.2000 Implementation of QAP: - QC of Equipment, Processor – 1.1.2000 & Associated Facilities - CME Annually – 1.1.2002 - Film Reject Analysis – 1.1.2002 - Audit of X-Ray Radiographs – 1.1.2002 (GP Clinic only)
  • 71. Circular to TKPK (Medical) and TKPK (Public Health) – 15.1.2001 All plans for facilities under Act 304 to be submitted and approved by Radiation Health and Safety Branch, Engineering Services Division before commencement of installation/renovation All related equipment and facilities to be tested, commissioned and verified to conform to safety and performance standards before clinical use
  • 72. Cont… Implementation of QAP • Quality control (QC) of equipment, processors and associated facilities • Monitoring and analysis of film reject rate • Continuous Professional Education (CME)
  • 73. Procedures To Apply For A License (Private) or Getting Approval (Public) STEP 1 Requirements to BUY & STOR Irradiating Apparatus STEP 2 Requirements to USE Irradiating Apparatus
  • 74. Step 1 Documents required to apply for BUY & STORE Irradiating Apparatus  Application form (private) or letter of intent (public)  Application/Licence fee (private)  Copy of current APC The address of practice stated in APC shall be the same as the address of where apparatus is to be stored or used  Layout plan of the premises  Detailed plan of the room where the apparatus will be located  Description of irradiating apparatus
  • 75.  FACILITIES Layout plan of premises Layout plan of premises shall indicate - Location of the x-ray room, darkroom & occupied area in the premise - All plan shall be in technical drawings & the scale shall be in metric (S.I) unit Note: No licence will be issued for X-ray practice in free standing laboratory where there is no doctor practicing in the premise
  • 76.  FACILITIES Detailed Plan of X-ray Room & Dark Room Detailed Plan of X-ray room shall clearly specify the following : i. Dimension of the x-ray room ii. Material used and thickness of the wall, ceiling and floor iii. Position, size & material used for the windows, doors and other openings iv. Position of the apparatus in the x-ray room v. Position of the operating console/control area vi. Warning light/sign at the door of the room
  • 77.  X-RAY ROOM- Layout and Dimension Type of Equipment General X-Ray * Fluoroscopy Plan Spec. Dimension of the room 3.0 m x 4.0m 6.0 m x 4.0m Thickness of Shielding at the 2.0mm Pb eq 2.0mm Pb eq Doors and Walls Dimension & Thickness of Lead 1.2m x 1.2m x 1.2m x 1.2m x at the Chest Wall 2.0mm Pb eq 2.0mm Pb eq Dimension & Thickness of Lead 35cm x 30cm x 100cm x 50cm x Glass Observation Window 2.0mm Pb eq 2.0mm Pb eq Dimension & Thickness of Lead 1.2m x 2.5mx 1.2m x 2.5mx at the Floor (upper floor) 2.0mm Pb 2.0mm Pb * Control panel outside with examination table Cont….
  • 78.  X-RAY ROOM- Layout and Dimension Type of Equipment Mammography CT Scanner Plan Spec Dimension of the room 2.5 m x 3.0m 5.5 m x 4.0m Thickness of Shielding at the 1.0mm Pb eq 2.0mm Pb eq Doors and Walls Dimension & Thickness of Lead NA NA at the Chest Wall Dimension & Thickness of Lead NA 100cm x 50cm x Glass Observation Window 2.0mm Pb eq Dimension & Thickness of Lead NA 1.2m x 2.5mx at the Floor (upper floor) 2.0mm NA - Not applicable Cont….
  • 79.  X-RAY ROOM- Warning Signs - All entrances to x-ray rooms shall be marked R with a warning sign - Consist of a three- blade design using the radiation caution colours, that is black for the design and yellow for the background. 1.5 R  R is the radius of theis correct ? Which one inner 5R circle and 5R is not less than 7.5 cm MS 838:1985 Cont….
  • 80. New Radiation Symbol ???? New Symbol launched to warn public about radiation dangers - supplementary symbol aims to help reduce needless deaths and injuries, IAEA – 15 February 2007
  • 81.  X-RAY ROOM- Warning Light All entrances to x-ray rooms shall have a light that is illuminated prior to exposure or when fluoroscopy is in progress The warning light should be red in colour (yellow or amber may also be used) MS 838:1985 Cont….
  • 82.  DARKROOM- Dimension & Location Minimum Dimension of = 1.5m x 2.0m Darkroom Location of darkroom shall not be in the direction of the useful beam. MS838:2007
  • 83. Step 2 Requirements to STORE & USE Irradiating Apparatus • Personnel & Licensee/Org Yg Bertanggungjawab Training Supervisor RPO Operators • Facility X-ray Room Dark room • Equipment X-ray Machine Processor/cassette/Viewer, etc • Procedures Local rules, etc
  • 84. Requirements to STORE & USE Irradiating Apparatus  Licensee/Org Yg Bertanggungjawab : GP clinics/Non X-ray Sp. Clinics/Health Clinics Registered Medical Doctor undergo 40 credit hours training program (new applicant) Hospital/Radiological Clinic Registered Med. Doc/Pengarah@ Radiologist Attend continuous professional education (CME) program
  • 85. Requirements to STORE & USE Irradiating Apparatus  Supervisor : GP clinics/Non X-ray Sp. Clinics/Health Clinics Registered Medical Doctor Attend yearly continuous professional education (CME) program Hospital/Radiological Clinic Radiologist Attend yearly continuous professional education (CME) program
  • 86. Requirements to STORE & USE Irradiating Apparatus  Radiation Protection Officer (RPO) : GP clinic/Non X-ray Specialist Clinic Registered Medical Doctor or radiographer Attend yearly continuous professional education (CME) program Hospital/Radiological Clinic Med. Physicist/Radiologist/radiographer Attend yearly continuous professional education (CME) program
  • 87. Requirements to STORE & USE Irradiating Apparatus  X-ray Operator : GP clinic/Non X-ray Sp. Clinic undergo 50 credit hours training program (new operator); Attend continuous professional education (CME) program yearly Having a personnel monitoring devices do a medical surveillance once in 3 years
  • 88. Training Syllabus For New Licensees & New Operators Doctors applying for new licences and newly employed operators are required to undergo the following courses before they are permitted to use the x-ray equipment Mod. 1: Radiation Safety Awareness 9 cr. hrs Mod. 2: X-ray Equipment and Associated 10 cr. hrs facilities Mod. 3: Clinical Practices 31 cr. hrs Mod. 4: Radiographic Techniques and QAP 21 cr. hrs TOTAL : (Module 1, 2 & 3 – for operators) 50 cr. hrs (Module 1, 2 & 4 – for doctors) 40 cr. hrs
  • 89. Existing X-ray Operator* 1. X-ray operators currently employed in the clinics and have been trained in the Orientation Programme conducted by the College of General Practitioners X-Ray Society of Malaysia or ANM 2. Workers trained in programme approved by the Licensing Authority – the training syllabus and facilities would be vetted before approval is given 3. Medical practitioners * Subjected to do chest & extremities only
  • 90. Requirements to STORE & USE Irradiating Apparatus Hospital/Radiology clinic Employment of at Least 1 Radiographer Mammography procedures shall be performed by a qualified female radiographer trained in mammography Attend continuous professional education (CME) program yearly Having a personnel monitoring devices Do a medical surveillance once in 3 years
  • 91. Medical Surveillance (Buku LPTA/BM/5) Nota: Pemeriksaan x-ray dada hanya perlu Question: dibuat utk jangkamasa lima (5) tahun sekali; atau apabila difikirkan perlu oleh Do you require to pengamal perubatan berdaftar yang do chest x-ray for diluluskan. medical check-up every time?
  • 92. CME All personnel All personnel/operators (include licensees) are required to attend CME programme to update their knowledge in order to keep abreast of the current practices in radiology annually. The training programme may include one of the following : • Radiation protection pertaining to the use of x-ray equipment • Radiographic techniques • Image quality criteria and requirements • X-ray reporting • Management of QAP • Film processing • Update in radiology imaging
  • 93. CME All personnel The above may be achieved :  By attending courses organized by other agencies/ organizations/ societies/ ect  Peer reviewed educational programmes/ distance learning programmes available either on the internet or through posts
  • 94.  FACILITIES & X-RAY EQUIPMENT Safety and Performance Standard QC of Equipment and Associated Facilities:  Tested & certified by consultant medical physicist approved by MoH – Class H (certification)  Submit certificate with summary report and full report to MoH
  • 95.  FACILITIES & X-RAY EQUIPMENT Safety and Performance Standard Facility/ Parameter Optimum Achievable Std Equipment Machine Irradiating performance As specified in the Standard  Apparatus parameter Exp. rate at every occupied outside the x-ray room and at the X-Ray Room Scattered Radiation position normally occupied by the operator at the control area shall not exceed 10mR in one week Condition of the Dark Room No light leakage dark room No light leakage Condition of all the Cassettes Film and screen should be in good cassettes contact
  • 96.  ADDITIONAL REQUIREMENTS Monitoring & analysis of film reject rate  Monitoring and Analysis of Film Reject Rate A report of monitoring and analysis of film reject rate shall be submitted every year. It should include the following: i. Monitoring Period ii. No. of film used iii. No. of film rejected and percentage • Corrective action taken when reject rate > 10%
  • 97.  ADDITIONAL REQUIREMENTS Audit of X-Ray Radiographs  Audit of X-ray Radiographs* i) Film Audit by Radiologist 10 x-ray radiographs selected randomly from GP’s clinics will be audited by radiologist based on established criteria and standard under circular issued on 21-10-1999. For each radiograph a minimum score of 7 is required to pass the audit. At least, 7 out of 10 films audited should meet the minimum score of 7 before they are considered to have pass the overall audit * For GP’s Clinic/Sp. Clinic only
  • 98.  ADDITIONAL REQUIREMENTS Audit of X-Ray Radiographs ii) Letter from Fomema (for Fomema panel’s clinics) Letter from Fomema to confirm that clinics are participating regularly in the X-ray Quality Control Programme of Fomema and x-ray films taken are satisfactory and adhere to the SOP
  • 99. Question Does ‘radiation leave’ cover under Act 304 or subsidiary regulations ? Answer NO Perintah Am Bab C – 47 Cuti tugas khas perubatan (14 hari) 
  • 100. SUMMARY Documents required to BUY/ STORE Irradiating Apparatus Documents Required Private Public Completed Borang LPTA/BP/3 or letter of intent   Application fee & License fees   Copy of current APC   Layout plan of the premises   Detailed plan of the X-ray room where the apparatus will be located   Catalogue/detailed of the apparatus to be licensed & copy of supplier license  
  • 101. Cont.. Documents required to STORE/USE Irradiating Apparatus Documents Required Private Public QC of Equipment Certificates   Licensee/supervisor/RPO – CME   Operators – Med. check up/Film badge/ CME   FRRA Report   Audit Film Report *   * GP Clinics
  • 102. Summary OVERALL Protection & Image Quality Safety
  • 103. Thank You For Your Attention
  • 104. PERINTAH-PERINTAH AM BAB C: CUTI 47 Cuti Khas Perubatan Kelayakan : (i) Pegawai yang menjalankan tugas x-ray sepenuh masa dan terdedah kepada pancaran x-ray (ii) Pegawai di pusat-pusat perubatan tertentu di mana jenis- jenis tugas yang dijalankan adalah atau tidak digemari. Pusat-pusat perubatan ini hendaklah seperti yang diluluskan oleh Ketua Pengarah Perkhidmatan Awam dari masa ke semasa TEMPOH : 14 hari setahun. Tidak boleh dikumpul dan hendaklah diambil dalam tahun yang ianya diperolehi Back
  • 105.  X-RAY EQUIPMENT Safety and Performance Standard (General X-ray) OPTIMUM ACHIEVABLE REMEDIAL SUSPENSION PARAMETERS STANDARD LEVEL LEVEL 1. X-Ray Generator ii) Accuracy of kVp Max. Deviation ± 5% >5% > 20 % or ± 5kV whichever is smaller. ii) Accuracy exposure time Maximum Deviation : a) for time ≥ 0.1sec ± 10% > 10 % > 25 % b) for time < 0.1 sec ± 20% > 20 % > 30 % Maximum deviation ± > 10 % or >30 % or iii) Exposure baseline 10% baseline reproducibility >50 % > 20 % iv) Exposure linearity Maximum deviation : 10% > 10 % or > 30 % or baseline baseline >20 % >50 %
  • 106.  X-RAY EQUIPMENT Safety and Performance Standard (General X-ray) OPTIMUM ACHIEVABLE REMEDIAL SUSPENSION PARAMETERS STANDARD LEVEL LEVEL 2. X-Ray Beam Limitation ii) Beam Collimation Max. misalignment 1 o o o >1 >3 of SID on any side o o o ii) Beam perpendicularity Less than 2 >2 >3 3. X-Ray Beam Filtration mm Al mm Al Below 50 kVp 30 0.3 < 0.3 40 0.4 < 0.4 50 to 70 50 1.2 < 1.2 60 1.3 < 1.3 70 1.5 < 1.5 > 70 80 2.3 < 2.3 100 2.7 < 2.7 130 3.5 < 3.5 Cont….
  • 107.  X-RAY EQUIPMENT Safety and Performance Standard (General X-ray) OPTIMUM REMEDIAL SUSPENSION PARAMETERS ACHIEVABLE LEVEL LEVEL STANDARD 4. Image Quality i) Resolution Please specify Baseline ± the resolution 2 group ii) Contrast and contrast and - attach test film 5. Leakage Radiation Exposure from the leakage 0.1mGy (10mR) > 0.1mGy > 1.0 mGy radiation at 1m from the x-ray (10mR) (100 mR) tube in an hour at every rating specified by the manufacturer. [back]