As the responsible Distributor and/or Installer:
- Have you registered as a Vendor/Assembler, as necessary, in the applicable 35 States that require registration?
- Have you submitted the State required installation report(s) to the State Radiation Control Agency in the time required?
- Do you have a documented means of informing the owner/end user of their x-ray machine registration and regulatory compliance responsibilities?
- Have you informed the State Radiation Control Agency for any “Out of State” x-ray machines you own and intend to bring into that State temporarily? (NOTE: There are several States that do not have an Out of State provision in their registration regulations, therefore; the distributor MUST register the x-ray equipment, including for trade shows and demonstrations. (Examples: Nevada and California).
- Does your company have a required written Radiation Protection Program if you have machines located at your site?
- Is your Radiation Protection Program audited annually as required?
- Have your staff, sales force and field service personnel received State required regulations & radiation safety training?
- Have your field service personnel been provided with documented Manufacturers industrial x-ray equipment training that qualifies them to perform their servicing duties (Manufacturer’s responsibility)? (NOTE: You will need this document, in part, to submit with your vendor/assembler registration applications for most States.)
- Have your Field Service personnel been issued a primary dosimetry badge and a calibrated radiation survey meter? (NOTE: You will need this information, in part, to submit with your vendor/assembler registration applications for most States.)
- Are your Field Service personnel specifically registered in those 13 States that require individual registration?
- Do you have a program in place to routinely review dosimetry results and to ensure your radiation survey meter(s) are calibrated annually? Do you maintain a copy of all radiation meter calibration certificates on site?
- Did you know some States require each Sales & Field Service Technician to be listed individually on the Vendor/Assembler registration? Colorado requires the Field Service Technician to take a regulations exam every 2 years. Minnesota requires each individual Field Service Technician be registered independently regardless of who they are employed by?
If you answered “NO” to any of these regulatory requirements listed above, or you are not sure, then you are likely in non-compliance with State regulations and YOU are in need of guidance and assistance from RCE Consulting.