AAPM Cautions Oregon Against Granting Training Exemption for Dermatologists

The American Association of Physicists in Medicine (AAPM) submitted a comment letter to the Oregon Radiation Advisory Council (RAC) on January 17, 2018, advocating against a request for exemption from training regulations that would allow dermatologists to treat non-melanoma skin cancers with superficial radiation therapy devices after only 16 hours of manufacturer training. The request for exemption provides a method of modifying regulations on a case-by-case basis without going through the rulemaking process. The RAC is now considering the request for exemption of Sensus Healthcare, the manufacturer of the Sensus SRT-100™, an updated version of an orthovoltage style x-ray unit, that uses innovative surface applicators for treating skin lesions.

At present, there is a renewed interest by dermatologists to use radiotherapy to treat skin cancers. While superficial and orthovoltage equipment has long been utilized for treatment of skin cancer, many dermatologists now in practice did not receive radiation medicine and/or radiation safety training during their residencies. At present, only a few dermatology residency programs train residents in radiation medicine and/or radiation safety. The Sensus devices and similar devices by other manufacturers use electronically-generated low-energy radiation sources (ELS) designed to deliver low-energy radiation at a high dose rate.

With this in mind, AAPM National and the Northwest Chapter worked together to craft a comment letter opposing the grant of an exemption from § 333-123-0015 (1) of the Oregon Code, which requires 200 hours of instruction to include basic radiation techniques in patient safety and radiation risk for the authorized use of therapeutic radiation machines. In its letter, AAPM recommended that dermatologists using radiation therapy devices (SRT devices) receive the training and education specified in Oregon's current regulations to ensure the safety of patients and healthcare personnel.

We will keep you advised of developments in this area. See the AAPM Government Relations webpage for full text of the comment letter. If you have any questions or would like additional information on this issue, please contact Richard Martin, JD, AAPM Government Relations Program Manager.