New York Vet X-Ray Registration and Radiation Safety

Registration or machine control

New York registers radiation installations with operable or intended-to-be-used radiation equipment through the Department of Health, unless registration with the New York City Department of Health is accepted for installations under the NYC inspection program. A new installation not already registered must apply between 60 and 30 days before establishment; renewal applications are due between 60 and 30 days before certificate expiration; and operator or location changes use the same 60-to-30-day advance window. A certificate of registration is issued for a period not to exceed two years — except that the Department may issue a certificate for a longer period in order to stagger expiration dates for administrative purposes — is not transferable, must be conspicuously posted, and changes affecting registration information must be reported to the Department in writing within 10 days. ¹

For veterinary radiographic installations, New York requires beam-restricting collimation, diagnostic protective tube housing, required filtration, and a dead-man exposure switch. During exposure, only persons required for the procedure may be in the room; mechanical supporting or restraining devices must be used when an animal must be held where practicable; animal or film holding is allowed only under clinically necessary extreme conditions; holders wear at least 0.5 mm lead-equivalent gloves and 0.25 mm lead-equivalent aprons, keep body parts out of the useful beam, and are exposure-monitored; pregnant women and persons under 18 may not hold animals or films. Portable/mobile units must have a dead-man switch cord long enough for the operator to stand at least six feet from the animal patient, x-ray tube, and useful beam. ²

Safety procedures and operator duties

Structural shielding for fixed installations: the control apparatus for fixed radiographic equipment must be located in an adjacent room or in a fixed booth within the same room composed of radiation shielding to a minimum height of seven feet; the control booth must either be arranged so that radiation has to be scattered at least twice before entering the booth, or be provided with a protective door interlocked so that the x-ray tube cannot be energized unless the door is closed; and the operator must be able to see the animal patient by means of a mirror or through a window of sufficient lead equivalence, placed so the operator is always in a shielded position. A practice building or remodeling a fixed x-ray room must meet these requirements. ²

Fluoroscopic installations: if the practice operates fluoroscopy, 10 NYCRR 16.54(c) adds: the fluoroscopic exposure switch must be of the dead-man type; equipment must be constructed so the entire cross section of the useful beam is always intercepted by a primary protective barrier (usually a lead glass screen or image intensifier assembly), with the exposure terminating automatically when the barrier is removed from the useful beam; minimum filtration applies; protective gloves and aprons of at least 0.25 mm lead equivalent each must be made available and worn by the fluoroscopist during every examination, and worn by all other persons in the fluoroscopic room unless measurements indicate they are not needed; and only persons needed in the fluoroscopic room may be present during the exposure. Mobile fluoroscopic equipment additionally requires a cone or spacer frame limiting source-to-skin distance to not less than 12 inches in the absence of a tabletop, image intensification at all times, and construction making it impossible to operate the machine unless the useful beam is intercepted by the image intensifier. ²

Related workplace-safety context

New York operates an OSHA-approved State Plan for state and local government workers only. Private-sector employers and workers are covered by federal OSHA, so the federal OSHA baseline in this kit remains the operative OSHA framework for a private practice. New York does, however, impose a separate private-sector workplace-safety duty outside OSHA — the NY HERO Act, below — which a New York practice must keep on file alongside the federal OSHA documents in this kit. ³

NY HERO Act (Labor Law 218-b) — airborne infectious disease exposure prevention plan. New York Labor Law Section 218-b requires each private employer — "any person, entity, business, corporation, partnership, limited liability company, or association employing, hiring, or paying for the labor of any individual," excluding government employers — to establish an airborne infectious disease exposure prevention plan, either by adopting the model standard published by the Commissioner of Labor for its industry (or the general model standard) or by establishing an alternative plan that equals or exceeds the model's minimum standards. The employer must provide the plan to employees in writing (and to each newly hired employee upon hiring), post it in a visible and prominent location within each worksite, and include it in the employee handbook if the employer provides one. ⁴