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U.S. Department of Health and Human Services

Radiation-Emitting Products

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If two or more medical physicists perform an annual physics facility survey or unit survey can each count it towards meeting their continuing experience requirement?

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Section 900.12 (e)(9) requires that the annual medical physicist facility survey include:

  1. Performance of the annual tests and the phantom image test
  2. Evaluations of the results of all QC tests conducted by the facility and of any corrective actions taken

If only part (a) of the facility survey as described above is performed, the survey can be counted as a unit survey only.

Section 900.12(e)(9) states that each survey be performed by an individual. FDA believes that two medical physicists cannot jointly (simultaneously) perform a survey on a mammography unit or QC records and gain adequate hands-on experience to be counted toward the continuing experience requirement. However, two or more physicists can perform separate surveys individually at different times on the same unit and/or QC records and count it towards the requirement.

The one exception that FDA recognizes is if a trainee or requalifying physicist performs a unit or facility survey under direct supervision. If such supervision includes both parts (a) and (b) above, both the supervisor and supervisee may receive credit for one facility survey. If only part (a) is performed under direct supervision, then the supervisor and supervisee both may receive credit for one unit survey. Only one trainee or requalifying physicist can be supervised at any one time.

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