Testimony of _____________________________, representing the
New Hampshire Society of Radiologic Technologists
January 13, 2016
Testimony in Support of Senate Bill 330
Mr. Chairman and members of the committee, my name is
__________________________________ and I represent the New Hampshire Society of
Radiologic Technologists, a professional organization founded for the express purpose of
enhancing, through education and advocacy, the proper and safe delivery of medical
imaging and therapy services. With me today are registered radiologic technologists and
members of the NHSRT. We welcome the opportunity to appear before you today during
these hearings and commend the New Hampshire General Court for its attention to this
very important subject.
We have all heard considerable concern regarding risks from radiation exposure.
And yet, less than 1 percent of public radiation exposure to ionizing radiation is
attributable to the normal operation of nuclear power plants. The FDA Bureau of
Radiologic Health has estimated that 30 percent of exposures to man-made radiation are
unnecessary, and percent to 10 percent of the unnecessary exposures may be attributed to
repeated x-ray examinations. Since its discovery in 1895, x-radiation has provided
enormous benefits to society primarily as a life-saving tool in the diagnosis and treatment
of disease. Through the 100-plus year history, the use of the x-ray in the medical arts has
grown into a sophisticated science that plays a major role in the assessment of virtually
all diseases. In fact, nearly every individual present here today has had an x-ray
examination performed in the last year.
Data published by the federal government tells us that the number of U.S. citizens
receiving x-ray examinations has risen from 108 million in 1964, to 130 million in 1970,
to approximately 350 million in 1996, and the number of x-ray and other diagnostic
imaging examinations performed each year is increasing in all age groups. This marked
increase in x-ray usage is attributed to greater sophistication of equipment such as threedimensional computed tomography and magnetic resonance imaging. Americans now
receive more than 50% of their annual radiation exposure from medical imaging
examinations.
New Hampshire is one of only 10 states that do not have education and
certification standards in place for persons performing the most common medical
imaging examination, diagnostic x-rays. Diagnostic x-rays differ from other man-made
radiation sources. Most human exposures to radiation are meant to cause a detrimental
effect, such as the nuclear bomb. Exposure to radiation through an x-ray procedure
produces a positive effect, a diagnostic image of the human body. The production of
radiation as used in the practice of medicine is an invaluable tool in the diagnosis and
treatment of disease. Even so, the use of radiation in medicine is not without risks and an
inherent potential of biological damage to healthy tissue. Any exposure to ionizing
radiation, however small the dose, increases the risk of developing cancer, leukemia,
cataracts, blood disorders and birth defects in developing fetuses. Any unnecessary
exposure therefore produces a risk without benefit to the patient.
Currently, a health care facilities and physician offices in New Hampshire using
x-ray equipment are under no statutory obligation to ascertain or require any credential or
specific education of the person employed to operate the imaging equipment. Literally,
anyone off of the street can be hired this morning and be operating this potentially
dangerous equipment this afternoon. Radiation is not detected by the senses of sight,
hearing, touch, smell or taste. Without sufficient knowledge of its application, the
operator has the potential to produce biological damage not only to the patient, but to
himself or herself as well.
Over the years, at both the state and federal levels, significant steps have been
taken to protect public health through manufacturing regulations for electronic products
such as x-ray and other medical imaging equipment. However, like your car, the operator
determines the use and abuse of this equipment. No one would permit his or her car, with
all of its safety features, to be driven by someone who has never been taught to drive.
And yet, we allow untrained operators of medical imaging equipment to expose the
patient to radiation that can affect future generations.
Forty states have developed licensure programs or adopted regulatory processes
for radiographers who perform x-ray examinations. One of the 40 states—California—
submitted a report to their legislature after 10 years of requiring licensure for radiologic
technologists. The report showed that for the 10-year period, overall medical fees
increased 92.7% throughout the state, while fees for radiology services only increased
59.2%. Licensure laws for radiologic technologists have not caused increases in the costs
of radiology services, but rather has helped to reduce costs of health care through
knowledgeable radiologic technologists competent in reducing not only radiation
exposure to the consumer-patient, but also in reducing waste of medical supplies,
technologist, physician and patient time and the wear of radiologic equipment from
improper use.
Without licensure in place, patients may receive inconsistent care which leads to
excessive health care spending and diminished quality of care. A federal report shows
that without consistent operator standards:

A patient undergoing the same x-ray examination may receive 100 times more
radiation in one hospital or clinic as in another.

In states without licensure, up to 40 percent of personnel administering ionizing
radiation for medical purposes may not have received any formal education in radiologic
technology.

80 percent of the medical radiation the patient receives is administered in facilities
other than a hospital.

One patient receives more radiation from an x-ray examination of the abdomen
than the entire exposed public received from the Three Mile Island incident.
There are 1,652 registered radiologic technologists practicing in New Hampshire
that have demonstrated their competency through education and voluntary certification
through the American Registry of Radiologic Technologists and other certification
bodies. There is no way of knowing how many people with minimal training and no
certification are operating x-ray and other medical imaging equipment in New Hampshire
and administering potentially harmful ionizing radiation to human beings without having
demonstrated scientific knowledge, technical understanding, clinical competency or
professional responsibility for the practice of proper radiological procedures.
Sadly, the patient is rarely in a position to judge either the qualifications of the
operator or the quality of the examination, let alone the radiation dosage. The chest x-ray
examination when performed by an uneducated, untrained operator has the potential to
deliver 100 times the radiation dose to the patient as the same procedure performed by a
properly educated radiologic technologist. We would remind you that this medical
radiation is produced solely by the actions of the operator. Properly calibrated equipment
and well-educated radiologic technologists are primary elements in the safe delivery of
this radiation. Lacking this education, the unqualified operator poses a serious threat to
the patient.
The performance of even the most basic and routine x-ray examinations require
substantial knowledge and understanding of the safe operation of x-ray equipment,
selection of exposure factors, selection of image recording systems, radiation beam
adjustment, proper patient positioning and knowledge of human anatomy, physiology and
pathology.
From its inception, the New Hampshire Society of Radiologic Technologists has
recognized that formal education, voluntary certification coupled with ethical obligation
is a controlling factor in the competence of the individual and in the reduction of
unnecessary radiation to both the patient and the practitioner. As educated radiologic
technologists, we strive to eliminate unnecessary radiation, and optimize that which is
needed to produce a diagnostic image. We have voluntarily submitted to examination
and have met the educational standards prescribed by the profession.
The New Hampshire Society of Radiologic Technologists does not believe there
is an alternative to licensure standards. We remain firm in our opinion that without state
statutory standards delineating the qualifications of persons who perform medical
imaging and radiation therapy procedures, the public will remain unprotected and at the
mercy of untrained personnel. Currently in New Hampshire the state does not have the
ability to review the credentials of radiologic technologists before issuing a license to
practice since there is no licensure. The lack of licensure also reduces the state’s ability
to sanction unscrupulous individuals operating imaging equipment or investigate charges
of improper conduct. Because of the unique nature and inherent danger of radiation, the
NHSRT believes that every patient undergoing a medical imaging examination has the
right to have that examination performed properly and with minimal risk by a qualified
practitioner.
A voluntary certification process for medical radiologic technologists through the
American Registry of Radiologic Technologists (ARRT) has existed for more than 80
years. But these credentials are voluntary and are not a condition for practice in New
Hampshire. Consequently, the voluntary credentialing programs cannot effectively
impact the radiation health and safety of the citizens of New Hampshire since noncertified personnel can still administer medical radiation examinations.
For those individuals not certified by the ARRT or other organizations, a
performance-based examination can be utilized as a measurement tool and a prerequisite
for licensure. The ARRT is currently cooperating with licensure boards in many states
by offering their examinations to candidates identified by the states. These
considerations are offered as substantiating evidence that using existing national
voluntary standards can decrease facilitation, implementation and costs to state
governments.
I realize there may be opposition to certain areas of this bill. I would caution you
that it would jeopardize any sound patient protection program in New Hampshire if the
law was to exclude any occupation from meeting the minimum qualifications that would
guarantee the consumer-patient’s safety from excessive radiation.
We commend the New Hampshire General Court for its interest and timely
concern with respect to the potential health hazards of medical diagnostic x-rays resulting
from the lack of proper safeguards and qualifications of persons operating ionizing
radiation equipment. We believe that this issue demands prompt and effective action.
We urge the Committee to continue its effort to seek a sound legislative solution to this
problem which we believe is essential to protect the rights of the people of New
Hampshire to properly performed radiologic examinations and from the potential hazards
of excessive and unnecessary medical imaging examinations and radiation therapy
procedures. Thank you.