Regulatory Brief

 Radiation Protection Guidance for Diagnostic and Interventional X-Ray Procedures

Radiation Protection Guidance for Diagnostic and Interventional X-Ray Procedures


Docket Number EPA-HQ-OAR-2010-1064; Radiation Protection Guidance for Diagnostic and Interventional X-Ray Procedures


Brief Description:

The U.S. Environmental Protection Agency (EPA) announced the availability of the opportunity to comment on the draft Radiation Protection Guidance for Diagnostic and Interventional X-Ray Procedures. When finalized, this document will replace which will replace the 1976 Federal Guidance Report No. 9, ``Radiation Protection Guidance for Diagnostic X-rays.'' 

AVMA Response:

Regarding the sections of the Draft specific to veterinary medicine, we are deeply concerned with the Draft’s guidance pertaining to fractious animals (lines 3106 – 3108 and 3329 – 3330). The Draft seems to suggest that, as long as armored welding gloves are available, the veterinary team should continue with the procedure despite the animal’s distress and the danger it may present to itself and those around it. This is inappropriate. As experts in animal handling and care, we strongly believe that humane and appropriately applied restraint minimizes fear, pain, stress and suffering for the animal, and protects the animal and personnel from harm. A fractious animal may easily hurt itself, those attempting to restrain it, and others. Additionally, the animal’s fear and distress may have severe and potentially fatal physiological effects. These adverse effects can be avoided by ensuring ongoing training in animal handling and behavior by all parties involved, and when handling is facilitated by the provision of pain relief, sedation, or anesthesia in advance of the procedure. The degree of restraint that should be applied is the least amount necessary to allow the specific procedure to be performed properly.

Background Documents:

Related AVMA Policies: