(Illinois). "The US Department of Education has considerable experience in credentialing professional bodies to accredit educational programs. It is appropriate for that department to continue this function."

Question 11 (N = 16)

How are personnel under authorized users supervised/trained in your facilities? How should they be? How are users trained in applications of new technology? What kind of ongoing training is provided? Should recertification be by test or evidence of continued education?

In response to this question we received 16 replies: 13 from professional associations, societies, and industry and 3 from the states. The overwhelming number of respondents agreed that continuing education and in-house training were the best means of assuring a competent work force. A smaller number suggested that testing was also important. And an even smaller number argued that there was a role for federal authorities in this broad area. As the AANC representative explained: "Regulatory agencies must look at the documentation of training, even if the training is part of a residency program, and determine that the regulatory requirements have been met" (AANC). The majority of comments, however, were of the following type: "The process of 'recertification' is best accomplished through well documented continued education" (ABNM). "Whenever new technology is introduced a special training is conducted by application specialists supplied by the manufacturer. Further in-house on-the-job training is provided by the medical physicist or equipment specialist who may have attended a special course at the factory" (ACMP). "I believe that recertification should occur by documentation of CME [continuing medical education]" (ACR). "Recertification could best be done as a combination of continuing education and testing'' (ARRS). "We believe that an individual working in any aspect of medical radiologic science should demonstrate minimum certification criteria with regard to an accredited education, practice experience and successful passage of a certification examination" (ASRT). "It is not clear what the optimum approach to re-certification is, but I feel that periodic testing, especially of highly experienced practitioners, would be strongly resisted and may well be unreasonable" (NYH-CMC). "Recertification can be accomplished by either testing or continued education" (Florida). "Illinois believes that the evidence of continuing education is adequate for re-certification of technologists at this time. The Department is aware of no medical profession or allied health occupation that is currently required to pass a test for re-certification" (Illinois).

Question 12 (N = 19)

What are your other concerns regarding the regulation of ionizing radiation in medicine?

In response to this question we received 19 replies: 12 from professional associations, societies, and industry; 6 from states; and 1 from miscellaneous



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