Radiation Safety and Compliance for Veterinary Premises

Picture of Grant Miller, DVM, CVMA Director of Regulatory Affairs
Grant Miller, DVM, CVMA Director of Regulatory Affairs

This article was originally printed in the Sept/October 2026 issue of the California Veterinarian magazine.

Following radiation safety best practices benefits patients and veterinary professionals. Within the veterinary practice, the radiology area is policed by the California Veterinary Medical Board (CVMB), the Department of Industrial Relations Division of Occupational Safety and Health (Cal/OSHA), and the California Department of Public Health (CDPH) Radiologic Health Branch (RHB). All entities enforce various sections of the California Health and Safety Code as well as Title 17 of the California Code of Regulations. Inspections by each entity are either complaint-driven or conducted randomly. Inspections can occur without prior notice.

During inspections, the agencies will look for the following:

Mandatory Postings

  1. “Caution- X-Ray Area” Sign: A sign needs to be posted in a conspicuous area near the X-Ray unit. This can be adjacent to the entrance of the room or near the X-Ray unit if the unit is not kept in a separate room. This sign fulfills a state safety requirement by notifying people that they are in proximity to a radiation area.
  2. Title 17 Posting: This set of radiation regulations must be either posted in the X-ray area or stored in a location designated by a posted notice in the X-ray area. This poster fulfills the state requirements, per Title 17, detailing radiation safety rules for radiographic and fluoroscopic units.
  3. 10 CFR 20: This set of radiation regulations, Division 10, Chapter 20 of the Code of Federal Regulations, pertains to standards of protection against radiation. Along with Title 17, 10 CFR 20 must be posted in the X-ray area or stored in an accessible location designated by a posted notice in the X-ray area. For mobile or ambulatory practices, this publication should be kept in a binder and carried in the vehicle for staff to review.
  4. Form RHB-2364 Notice to Employees: This form must be posted in a conspicuous location within the X-ray area. It fulfills a state safety requirement detailing standards for protection against radiation, which apply to both employees and employers.
  5. Radiation Safety Instructions: This form must be posted in a conspicuous location within the X-ray area (preferably near the control panel for the X-ray unit). This posting fulfills a state safety requirement and offers detailed information on applicable safety practices and procedures in the radiation area.
  6. Radiation Emergency Procedures: These need to be written and posted according to the specifics of the practice. They include what to do in the event of a radiation emergency, including emergency shutdown procedures for the unit. Radiation Emergency Procedures must be posted in the X-ray area, preferably near the X-ray control unit.

 

(For items 2-5 above, for mobile or ambulatory practices, these publications should be kept in a binder, carried in the vehicle, and should be available to staff for review.)

Mandatory Documentation

  1. Radiation Safety and Compliance Policy for Your Practice: This document serves as a basic policy for your practice and should reflect the specific radiation safety practices of your business. No two policies will be identical since no two veterinary practices are configured or run the same way.
  2. Radiation Safety Training and Documentation: Practices must be able to demonstrate that all employees (other than veterinarians or RVTs) who assist in the taking of radiographs have radiation safety training. As an option to fulfill this requirement, the Radiation Safety Manual with Radiation Safety Quiz is available through the CVMB. This manual, if used to fulfill the safety training requirement, should be reviewed with all applicable staff. The included quiz can be used as proof of radiation safety training. Completed quizzes should be kept in a dedicated file for inspection upon request. These records may not be kept in an employee file that includes financial information. The manual and quiz should be kept in a location where staff can access it. For fixed premises, this can be in a designated drawer or file, or in a designated electronic file folder. For mobile or ambulatory practices, this can be in a binder that is carried in the vehicle or kept electronically. Should you choose to develop your own Radiation Safety and Protection Program, it should follow the guidelines set forth in the Radiation Safety and Protection Program Requirement Guidance published by the RHB. You are not required to keep all components of your Radiation Safety and Protection Program in one consolidated document. However, all components do have to be documented and identified as being part of the Radiation Protection Program. Records of the Radiation Safety and Protection Program content, implementation, and audits must be maintained and made available for inspection. Whatever program you choose to develop should be reviewed annually to ensure that it remains compliant.
  3. Radiography Unit Registration: All radiography units must be registered with the CDPH RHB. Online registration information and forms can be accessed by scanning the QR code. Completed forms should be mailed to the California Department of Public Health – Radiologic Health Branch, MS 7610, Registration Unit, PO Box 997414, Sacramento, CA 95899-7414.

 

Additional Recommendations

Beyond these requirements, the CDPH RHB recommends that licensees develop a radiation safety program specific to their premise, which may include the following:

  • Periodic X-ray and radiation safety meetings with staff. In these meetings, it is a good idea to have printed materials and a staff sign-in sheet to prove attendance.
  • Dosimeter badges: Although not specifically required, badges are strongly recommended since you are required to be able to report exposure limits of employees. Occupational exposure should be recorded regularly (at least quarterly and preferably monthly). Also, law requires that an annual report of occupational exposure be provided to all individuals who are being monitored. Search for Radiation Dosimeter Badges online to access several companies that offer products and services.
  • Routine inspection of radiation safety equipment (e.g., gloves, gowns, thyroid shields) for cracks or creases.

 

If you have any questions about radiation regulations and your obligations as a licensee, please contact Dr. Grant Miller, CVMA Director of Regulatory Affairs, at (916) 649-0599 and select option 6 or gmiller@cvma.net, or visit cvma-watchdog.net and use the search function to find information on radiation regulations.

CVMA Radiation Compliance Kit

The CVMA offers a complete Radiation Compliance Kit at a discounted price for members. The kit contains all required postings and documentation necessary to keep you compliant. To purchase the kit or for more information on radiation compliance, visit the Regulatory Products page to purchase this product. 

This article is for informational and general educational purposes only. It is not intended to take the place of legal advice, nor should it be considered as a legal interpretation. Although significant effort has been made to ensure the accuracy and completeness of the information at the time of publication, the CVMA shall not be responsible for any errors or omissions, or any agency’s interpretation, application, or enforcement of the information presented herein.

The CVMA-PAC

It’s Not About Politics….It’s About Your Profession. The CVMA-PAC is a bipartisan political action committee whose purpose is to educate state legislators and candidates on issues of importance to the veterinary profession

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