Dental facilities with x-ray machines must now hire Qualified Experts (QEs) in radiation safety, approved by the Missouri Radiation Control Program (MRCP) to perform initial and periodic surveys (inspections).

The QE will evaluate radiation safety of the facility, usually to include machine performance, shielding and personnel monitoring. The QE will send evidence of the findings to the MRCP for any necessary follow up.

These inspections must be done whenever new facilities open or new x-ray rooms are added, and for existing facilities, prior to the QE Due Date assigned to your facility by MRCP. Most of these due dates begin, on a rotation, in 2017, and then every six years thereafter. This due date already has been mailed to your facility. Your facility also will be sent a reminder notice 90 days prior to the due date. Cone Beam CT machines must be inspected every three years.

If a new x-ray room is added, in addition to the machine inspection, the facility also must demonstrate that radiation shielding is adequate. This can be done by following a shielding plan evaluation by a Qualified Expert or at the time of an initial inspection on the new room prior to routine clinical usage.

Repairs of existing equipment or replacement of dental equipment in existing rooms do not require a mandatory survey. However, facilities are encouraged to contact their QE to discuss if additional safety testing may be prudent.

QE survey fees are not set or controlled by MRCP but by private arrangement between QE and facility. Type of equipment, numbers of machines and distance of travel for the QE may all factor into the cost.

• health.mo.gov/safety/radprotection
• Additional questions: MRCP@health.mo.gov or 573-751-6083

Inspection Due Dates PDF

This list was updated February 13, 2023 and will be updated annually. 

PDF List: Sorted alphabetically by CITY and then by Registration Due Date (soonest to latest). Once the PDF is open, you may click CTRL + F (Windows) or Command + F (Mac) for the search to open; then enter your first/last name or zip code to more quickly find your listing.

Machine Class: There is a field to distinguish machine class D vs E. Class E are those who have CBCT units, which now have to be inspected every 3 years, as opposed to other dental equipment which is on a 6-year cycle. MRCP tracks both of those dates and the due date for new equipment inspections (if a facility adds on a new room to their facility, increasing their x-ray inventory by +1). Therefore, the date in the list is the next time a facility needs a QE inspection. For >90% of those, they will need to get all x-ray equipment inspected by that date. 

The MDA suggests member dentists review the list of practices due for inspections in their component in the same time frame, and then connect with those practices to coordinate due dates with scheduled inspection services from one of the Qualified Experts (QEs) most frequently servicing dental practices.

Most QEs serving the dental community have stated that while they do have a home-base area, they will go to areas throughout the state (schedule allowing) and if there is enough work clustered to warrant it, will work to split travel costs among clients, or they will split travel costs if they can conduct inspections in route to a destination. For example, if they make trips to Joplin several times each year, along the way, they can stop in Rolla, St. James, Springfield, Nixa and Neosho to do inspections, thus aggregating the travel fee, making it much less for all.

An example of this process may include: Your office reviews the List of Members and contacts other practices in your area that are due in the same time frame. From this contact, you determine if they have scheduled a QE inspection. If so, you can inquire with that QE if they can inspect your machine(s) and others in the same trip and thus, what an estimate is based on these factors. Conversely, you may contact the List of QEs to inquire if they have any inspections (dental or other medical) scheduled in your area within the due date time frame and thus, what an estimate is based on these factors.

The MRCP maintains a list of Qualified Experts to come to your dental office and perform the required radiation equipment inspections. QE survey fees are not set or controlled by MRCP but by private arrangement between QE and facility. Type of equipment, numbers of machines and distance of travel for the QE may all factor into the cost.

• QE List: Click Here
  
  • With most commonly sought area of expertise, including Dental (Intra/Oral, Pano) and CT (+ Cone-Beam CT)

Does the list you provide contain any private information about member dentists? Are you providing this list to the QEs?

No. The list contains contact information that is public and it contains the date of the QE inspection. Further, we have protected the list so that it cannot be printed. The goal of providing the list is so that member dentists can connect with others in their areas to coordinate/aggregate inspections and thus, perhaps qualify for cost savings.

No. The MDA is not providing the member list to the QEs. We do not want QEs soliciting members based on their inspection due dates and instead, are providing the list to members only so members may initiate contact to one another or to a QE.

I have checked the list and find few other dental practices in my area that are due in the same month. Won’t this make it hard to group inspections for a cost savings? What if we all have inspection dates in the same year but different months? 

We encourage you to have your inspections done at the same time so that you can experience a potential discount from the QE, ESPECIALLY because the MRCP will give bonus time (up to 12 months from the next due date) if doctors get the inspection done early. 

For example, if one is due in January and one is September, and the QE comes in January, the doctor with the September date can get their inspection early but their actual 6-year cycle will not begin until their original September date. You cannot be past your inspection due date, but you can be early and use the bonus time to your benefit—to possibly group with other areas dentists and negotiate a reduced fee for inspection services from the QE.  

Why doesn’t the MDA endorse or create a contract with only one QE? Wouldn’t that save members time and money to just contact one?

The MDA has decided to not endorse any one QE due to various factors, some of which include: Not all QEs travel to all areas of the state; Depending on your geographic location, a QE may be located closer to you and thus will be more cost effective; QEs service all radiographic machines, not just dental; therefore, a certain QE may not be able to perform an inspection by the due date.

Further, we hope that as members communicate with one another and with QEs, that relationships will be established for future inspections and potential cost savings. For example, a QE may contact all dentists in a geographic area they are visiting for inspections and thus aggregate their services to offer discounts to individual practices.

My address (or other information) is incorrect on the membership list. How do I get it changed?

This list was generated by the Missouri Radiation Control Program. To request changes to your information, email MRCP@health.mo.gov or call 573-751-6083.

Notice

Effective March 1, 2017, the Missouri Radiation Control Program formalized a simplified route whereby certain radiation facilities that demonstrate better radiation safety practices will be eligible for an extension after their next QE inspection. 

Background

MRCP recognizes that not all facilities with radiation machines are equal when it comes to their internal practices; some already have taken voluntarily actions that enhance their radiation safety, and therefore are of reduced public health concern. The MRCP has always allowed facilities to apply for an alternative standard (inspection period) if they provide evidence that they present a clearly lower radiation safety concern than the normal facility classification. This update it merely a standardizing of this process—expanding and formalizing the existing process for facilities to apply. The MRCP is formally taking additional markers of radiation safety into account and allowing individual facilities to request an extension AFTER receiving their next QE survey with a grade of 0 or 1.

Inspection Extension Application Form

Extension Periods

Extension periods considered for each class are as follows (dental practices are either Class D (non-CBCT) and Class E (CBCT). 

In order to apply for extension, the following criteria must be met:

• Facilities must actively apply for the extension, with the application reviewed and approved by MRCP.
• The extension can be applied for only AFTER the facility’s next QE survey beginning 3/1/2017, provided the QE survey is graded either 0 or 1 (no items requiring correction).
• If granted, MRCP will inform the facility AS WELL AS the last QE of record of the extension, so that all concerned parties can update their records.
• Not all facilities are eligible for extension (mammography, radiation therapy, facilities that must meet other standards outside of MRCP jurisdiction, e.g. accrediting organizations, etc.).
• This is NOT a formal reclassification, but it is a renewable extension (that may be applied for after each successful QE survey).

In addition the facility requesting the extension must meet two (2) of (any of) the following criteria:

• Ongoing dosimetry (radiation badge) program (acceptable to MRCP) for all personnel occupationally exposed. See Focus article.
• For medical (non-industrial) imaging, exclusive use of digital image processing (CR or DR). 
• All exposures are made by ARRT registered Radiographic Technologists, trainees in JCERT-approved training programs (or the equivalent) under supervision, or board-eligible radiologists (by formal written facility policy). 
• Formal Preventative Maintenance (PM) arrangement with manufacturer representatives of x-ray and image processing equipment acceptable to MRCP (at least annual service; arrangement must be in writing). 
• Formal radiation safety committee* with routine meetings, and/or ongoing Quality Assurance program (acceptable to MRCP) focused on reducing unnecessary exposure and/or optimizing exam/treatment quality. (Documentation must be provided). Note, a “committee” would be comprised of more than just the dentist. There is no list of what should be covered in the documentation; rather the committee should focus on radiation safety and/or image quality and be formal, with meetings, measurable benchmarks and minutes. It would be functional and useful for the facility on an ongoing basis.
• Very Low workload. Documentation of fewer than 300 exams/year [25/month] for medical or veterinarian facilities, 300 exposures/year non-medical/industrial. (Documentation of workload must be provided, and diagnostic radiology facilities that have already been reclassified from B to C based on workload will not be eligible for additional extensions based on workload alone).

The MRCP has created a guidance document specifically designed for service reps to hand out to dental facilities that are just opening up or adding additional (+1) machines.

MRCP finds a lot of confusion when they contact facilities and tell them they need to either complete a registration or have a QE inspection, at which time they commonly report “the service company told me they took care of all the paperwork.”

The service company DOES send MRCP a form of new installs or major repairs, but that doesn’t replace the facility’s responsibility to update its registration with MRCP or get new rooms inspected!

According to 19 CSR 20-10.030(2) “The user shall notify the department in writing within 30 days of any change with respect to his/her radiation sources which may substantially increase or decrease the potential for exposure” and schedule an inspection of that machine within 90 days of the notification.

In this guidance document, a summary of requirements is included, but the overarching message is “if in doubt, call the MRCP office and we’ll figure out what you need to do.”

MRCP Guidance Document

I have been in practice for more than 25 years and have never heard of this and am sure my machines aren't inspected. Do I have to have this done? Effective January 1, 2014, it is the responsibility of the owner of x-ray machines to provide for both initial and periodic inspection of x-ray machines, and to ensure radiation shielding is adequate, through use of MRCP-approved Qualified Experts (QEs) in radiation safety. Therefore, you should contact the MRCP to register your location and numbers/types of machines. This registration will result in a Qualified Expert needing to visit your location (at your cots) to have the machines inspected. If you have a CBCT it will be every three years; for all other machines, it will be every six years.    

As far as I know my office has never had an inspection done, but I have only been sole owner for three years and just this week was the first I had ever heard of this requirement. Do I need to go ahead and have the inspection done or do I wait until I get notice of the survey inspection being due? I have a Sirona XG3D cone beam, a Nomad and two wall-mounted arms. In this situation, the dentist was unaware that cone beams need to be inspected every year and in speaking with the state, the MRCP did not show him as having a cone beam registered to his office. We also ascertained his other inspections are not due until 2019. Therefore, he needs to immediately register the CBCT with the state, according to 19 CSR 20-10.030(2) “The user shall notify the department in writing within 30 days of any change with respect to his/her radiation sources which may substantially increase or decrease the potential for exposure” and schedule an inspection of that machine ASAP (for CBCT this is a Class A machine and should be prior to clinical usage), but in any case, within 90 days of the notification. Although the dentist could go ahead with inspections of all his machines, including those not due until 2019, it may behoove him to wait, since he will need to have an annual inspection by a QE of his CBCT. 

In this last scenario, one could ask “What if, in 2019, the doctor’s CBCT is due in January and his other machines aren’t due until September of that year? Can he have them all done at the same time, even though his due dates are different? Yes. There is no penalty for having the regular (non CBCT) inspections done early. The MRCP will reset the doctor’s other machines to be the same month as the CBCT. 

In a related question, suppose I work with some other practices and we arrange for a QE to come do all our inspections within a day, because we’ll be given a “bulk” discount. What if we all have inspection dates in the same year but different months? Can we have our inspections done at the same time so that we can experience the discount from the QE? Yes. The MRCP will give bonus time (up to 12 months from the next due date) if doctors get the inspection done early. Therefore, if one is due in January and one is September, and the QE comes in January, the doctor with the September date can get their inspection early but their actual 6-year cycle will not begin until their original September date. You cannot be past your inspection due date but you can be early and use the bonus time to your benefit – to possibly group with other areas dentists and negotiate a reduced fee for inspection services from the QE.  

If I have a new radiation machine installed at my office, who is responsible for registering it with the state? Me or the installer (such as Goetze or Patterson)? The dentist is always responsible to ensure it gets registered with the state. The MRCP has created a guidance document specifically designed for service reps to hand out to dental facilities that are just opening up or adding additional (+1) machines. This is because MRCP finds a lot of confusion when they contact facilities and tell them they need to either complete a registration or have a QE inspection, at which time they commonly report “the service company told me they took care of all the paperwork.” The service company DOES send MRCP a form of new installs or major repairs, but that doesn’t replace the facility’s responsibility to update its registration with MRCP or get new rooms inspected!

If you have a machine that was manufactured after 1977, then it must be installed by a “certified” professional. That certified installed is responsible for notifying the state of their installation, at which point the state can contact the dentist to verify the install. However, some vendors are slow to submit their paperwork, with a delay of as much as 3-6 months. Additionally, sometimes a certified installer is not used and someone like an electrician may install a machine and may not submit the proper paperwork (which in itself is a violation of federal FDA regulations). Therefore, a dentist should always ensure the MRCP is notified. 

There are two scenarios/ways to notify the MRCP: 1) If it is a radiation machine that is replacing another, the dentist simply needs to call the MRCP to let them know which machine is being replaced within 30 days; no inspection needs to occur. 2) If it is a new radiation machine being installed in addition to others already existing in the practice, then … “The user shall notify the department in writing within 30 days of any change with respect to his/her radiation sources which may substantially increase or decrease the potential for exposure.” 19 CSR 20-10.030(2) … and should have an inspection (ideally) prior to routine clinical usage (practically) within 90 days from installation. 

I know my inspection date is 2018 for my existing units, but I am getting a new one installed next week. Does the new one require an inspection and if so, should I do all the inspections at the same time or just the new one and wait until the actual due date for the others? See above. If it is merely a replacement in an existing x-ray room/operatory, you should notify the MRCP and can wait to have it inspected with the other machines. If it is a “plus 1” machine – an additional machine to your existing inventory – you should notify the MRCP within 30 days and have it inspected no later than 90 days after installation because of the additional radiation exposure in the practice. 

I have three different practice locations and all three have different inspection due dates. Can I have them done all at the same time so that future inspection dates are synchronized? Yes, you can contact the MRCP and ask them about synchronizing your various office inspection dates. 

Follow-up with MRCP Program 

In the Spring 2017, the MDA followed up with John Langston, Bureau Administrator of the MRCP, on some additional questions since publishing this web page. Those questions and responses follow. You can find these and other FAQs on the MDA page and on the FAQ section of the MRCP.

Has the MDA’s effort to inform members resulted in calls to you with questions/concerns that you want to expose or allay? We get a fair number of questions, but most of them are specific to a given facility. The questions are nuanced, thus there has not been one big question. The answers to most general radiation safety questions can be found on the FAQ section of our website.

What, if anything, are the QE reports telling you? Are most machines where they need to be in terms of safety? Is there anything to learn from these reports, collectively? Because each QE can (within limits) use their own inspection forms, it’s difficult to get too far down in the weeds as far as specific details. However, based on the mandated summary data in a specific format that the QEs send the MRCP, I can give you some overall aggregate data for dental inspections conducted from January 1, 2014 through December 31, 2016 (the past two years). Something important to keep in mind: Routine QE inspections of existing dental facilities (that were already there prior to 1/1/14) did not routinely start until 1/1/2017. So the inspection results we have so far are primarily for newly installed equipment (new facilities), facilities that have relocated/moved, and CBCT facilities. Therefore, in most cases, these are facilities where the equipment tends to be installed more recently. Once the older equipment is inspected, there may be an uptick in findings that require corrective action.

CLASS D DENTAL (INTRA/ORAL & ROUTINE PANO EQUIPMENT)
341 inspections between 1/1/14–12/31/16
Grade 0 (no items of note, nothing to correct): 279 (82%)
Grade 1 (minor findings, suggested corrections [not mandated]): 47 (14%)
Grade 2 (significant findings, corrective action/service required w/in 30 days): 14 (4%)
Grade 3 (unsafe conditions, cease use immediately until corrected): 1 (<1%)

CLASS A DENTAL (CBCT EQUIPMENT)
409 inspections between 1/1/14–12/31/16
Grade 0 (no items of note, nothing to correct): 324 (79%)
Grade 1 (minor findings, suggested corrections [not mandated]): 66 (16%)
Grade 2 (significant findings, corrective action/service required w/in 30 days): 17 (4%)
Grade 3 (unsafe conditions, cease use immediately until corrected): 2 (<1%)

A dentist contacted us who is replacing a pano with a cone beam. He wanted to know if there were regulations regarding if it had to be in its own walled-off room? That speaks to overall questions about shielding that we get from a lot of facilities, dental included. We will get cold calls from facilities or vendors with a quick question “how much shielding do I need, or do I need anything?” That’s just not a question that has a quick answer other than “it depends.” Dental facilities need less additional shielding than most other facility types, but it’s still dependent on the number of machines, the location, the workload, the type of machines and their typical settings, etc. QEs can spend a lot of time trying to accurately calculate the proper amount of shielding. As noted on the information we sent back in 2014, our rules refer back to and require compliance with NCRP Report No. 145 Radiation Protection in Dentistry (which is the process of being revised). It’s a 190-page document that describes everything QEs (and facilities) need to take into account from a radiation safety standpoint, and it’s a large part of what a QE may refer to during inspections. For dental offices, the short story is, many (even most) won’t, but some will require additional shielding.