X-ray equipment registration

A buyer of a dental, chiropractic or veterinary practice should check radiation equipment records in due diligence. This entry covers Ontario only; check the rules where you are. Ontario regulates the installation and use of X-ray sources in part under Regulation 861 (X-ray Safety) of the Occupational Health and Safety Act, and the Ministry of Labour, Immigration, Training and Skills Development says an employer must register and receive approval from Radiation Protection Services before installing and using one.

Which route applies

The Ministry states that sources used on humans for treatment and diagnostic purposes are registered through the Ministry of Health, while its own form covers non-human use. Section 6 of Regulation 861 says an X-ray source shall not be installed or used in a permanent location unless an application for review, with plan location drawings, has been reviewed by and is acceptable to an inspector, subject to the exceptions in s.6(2) for some older installations. Section 3(2) excludes X-ray machines subject to the Healing Arts Radiation Protection Act from sections 5 to 8.

What a buyer should ask

• Which registration covers each unit, and in whose name it is held
• Whether the form has been updated and resubmitted, which the Ministry says is required when an X-ray source changes ownership
• Whether any unit was replaced or upgraded since it was reviewed, which the Ministry gives as an example of a change that can require an update
• Whether the seller will give the notice s.5(4) of the regulation requires, forthwith, when a registered employer ceases to have possession of an X-ray source

The dental practice buyer checklist shows where equipment records sit among the other items.