Guidance for completing the X-ray registration and application form

This resource does not replace the Occupational Health and Safety Act (OHSA) and its regulations and should not be used as or considered legal advice. Health and safety inspectors will apply and enforce these laws based on the facts they find in the workplace.

Background

We created this page to help stakeholders to register an employer and submit an application for review of an X-ray source, by filling out the X-ray registration form (Form ON00057E, Application for Registration and Installation of an X-ray Source).

In Ontario, the installation and use of X-ray sources is regulated, in part, by the Regulation 861 — X-ray Safety under the Occupational Health and Safety Act (OHSA). This regulation sets out radiation shielding requirements relating to the health and safety of workers exposed to X-rays.

X-rays for non-human therapeutic or diagnostic use must be registered with the Radiation Protection Services (RPS) at the Ministry of Labour, Immigration, Training and Skills Development.

X-ray sources that are used on live humans for treatment and diagnostic purposes must be registered through the Ministry of Health. Contact the X-Ray Inspection Service (XRIS) either:

• by phone at 416-327-7937
• by email at XRIS@ontario.ca

Opening the form

1. Download the form, Application for Registration and Installation of an X-ray Source, from the forms repository.
2. Navigate to the file on your computer and open the form with Adobe Reader. The form requires version 10 or higher to open. It will not open properly within other apps such as email or internet browsers.

Filling out the form

We’ve provided guidance about what to enter in some fields on the form.

Section 1: Applicant information

Please fill in all mandatory fields. This section of the form asks for registration information about the employer, including your:

• company name and business address
• contact information
• type of business

Applicant notes to reviewer

Section one also includes this optional field. Additional information can include the X-ray’s usage frequency, and the purpose of the X-ray.

See the guidance about the “File Attachments” field below regarding information you may want to provide in separate documents.

Section 2: X-ray source

This section asks for information about each X-ray source you are including in the application. It asks you:

• the nature of the application (the reason you are applying for approval of the source)
• when the source will commence operation
• the type of source
• the technical specifications of the source
• where the source will be located
• who will be responsible for directing the safe use of the source

Section 2 also asks you to:

• attach a floor plan for the locations where you will use the source regularly
• tell us about the occupancy and use of the area where you will use the source

The form can be used to apply for multiple X-ray sources. Please complete the information in this section for each X-ray you plan to use.

Attach a floor plan within this form for every fixed X-ray source and portable and mobile X-ray source that is used regularly in one location, including portable sources used regularly in a location(s). Please refer to “X-ray source type” below for the definition of a fixed X-ray source.

Nature of the application

Below the checkboxes there is a question that asks, “Is this application made in compliance with a Ministry of Labour, Immigration, Training and Skills Development (MLITSD) inspector’s direction?”

An MLITSD inspector who visited may have made an order or direction to apply for review of an X-ray source with RPS. An inspector will have documented any order or direction in a written field visit report. If an inspector has directed you to register or apply for review of an X-ray source then please select the “Yes” box.

X-ray source number 1

Operation of X-ray source

Please input the date which the X-ray is expected to become operational.

X-ray source type

Please select one box for the type of X-ray you are registering:

• Portable: any X-ray source designed for portable or mobile use and that is so used. Examples include handheld X-ray fluorescence (XRFs), and mobile X-rays for large animals like horses and cows.
• Cabinet: there are four requirements in section 17 of Regulation 861 that must be complied with where a cabinet X-ray is used — warning device, interlocks, radiation shielding, and warning signals with failsafe. Please refer to section 17 for specific information.
• Cabinet (walk-in): any X-ray source that is designed for a worker to enter into and fulfils the criteria set out in section 17 of Regulation 861. Please refer to section 17 of the regulation for specific information.
• Fixed: any X-ray source that is used in a permanent location or an X-ray source that is designed for portable or mobile use that is used regularly in one location. This includes “every three months”, “every year”, etc.

X-ray source specifications

The information in this section is required to calculate the workload of the X-ray source, which you then input into the form.

Most of the required information can be found on the X-ray itself and in its technical specifications brochure, including the maximum rated tube voltage and maximum rated current. Please contact the manufacturer or your equipment provider to access the technical specifications.

Manufacturer: please input the X-ray’s manufacturer here.

Model name and number: please input the X-ray’s model name and model number here.

Serial number: please input the X-ray’s serial number here. If the X-ray isn’t obtained, then please input “TBD” for “to be determined” when you receive your X-ray.

Identified on floor plan as: please input the name or identifier of the X-ray as shown in your plan drawing. If you have labelled your X-ray as “X-ray 1” on your plan drawing, then please input that here.

Maximum rated tube voltage: this information will be in the technical brochure. Please input the maximum number and not the number you are to use during operation.

Maximum rated current: this information will be in the technical brochure. Please input the maximum number and not the number you are to use during operation.

Anticipated maximum workload: workload is a measure of the cumulative X-ray output of the source. You can calculate it using the following two examples.

Pulse-type x-ray sources (example: veterinary use)

Workload equals the maximum current multiplied by the time it takes per exposure multiplied by the number of exposures per week, divided by 60 seconds per minute.

Pulse-type workload example:

• The maximum voltage and maximum current for separate x-rays would be in their technical specification brochures.
• Assume stated 7 mA for the maximum current as per the technical brochure.
• If it takes 1/10 of a second for one “snapshot”, or exposure, each time the equipment is used and you anticipate that you will use it 200 times per week, then:

Workload = (maximum current) x (time per exposure)^{footnote 1[1]} x (exposures per week) ÷ (60 seconds per minute)

= (7 mA) x (1/10 second) x (200 exposures per week) ÷ (60 seconds per minute)

= 2.33 (mA) x (minute) ÷ (week)

= 2.33 (mA) (minute) / week

= 2.33 milliampere-minutes per week

= 2.33 mA-min / week

2. Continuous-beam x-ray sources (examples: assembly lines that are always on, food inspection, baggage inspection)

Workload equals the maximum current multiplied by the hours per week it’s scheduled to be operational, multiplied by 60 minutes per hour.

Continuous-beam workload example:

• The maximum voltage and maximum current for X-rays would be in their technical specification brochures.
• Assume stated 5 mA for the maximum current as per the technical brochure and you anticipate that you will use it for 10 hours per week, then:

Workload = (maximum current) x (hours per week) x (60 minutes per hour)

= (5 mA) x (10 hours per week) x (60 minutes per hour)

= 3,000 (mA) (minute) ÷ (week)

= 3,000 (mA) (minute) / week

= 3,000 milliampere-minutes per week

= 3,000 mA-min / week

Location of X-ray source

Please input the name of the workplace and address of the location where the X-ray will be installed and used. For mobile or portable X-ray sources, input the location of where the machine is or will be stored off-hours.

Responsible person

Section 8 of Regulation 861 states that an employer shall designate a person, for each X-ray source, who is competent because of knowledge, training or experience in the use and operation of X-ray sources and in radiation safety practices, to exercise direction over the safe use and operation of the X-ray source, and shall advise a Director in writing of the name of the person designated.

Notification to a “Director” as required in Regulation 861 can be provided by completing the Application for Registration and Installation of an X-Ray Source and including the name of the competent person

The level of training that is expected or appropriate for the designated person is dependent on the hazard of the device. The regulation does not specify what level of training is required, but the responsible person is expected to be the resource in the workplace who is qualified because of knowledge, training and experience and is able to organize the work and its performance, and provide information and guidance on the device to others in the workplace. At minimum, the designated person must demonstrate knowledge of:

• the equipment being used and its operation
• knowledge of any potential or actual danger to health or safety in the workplace, including:
  • basic principles of ionizing radiation and how to protect workers from exposure to ionizing radiation
  • the use, care and limitations of personal protective equipment and the shielding requirements for the X-ray rooms
  • personal dosimetry — how, when and where to use it
  • The National Dose Registry (NDR) which tracks and reports occupational exposure to ionizing radiation through your dosimetry provider
  • emergency protocols
• The OHSA and the regulations that apply to the work, i.e. Regulation 861 — X-ray safety

Additionally, the designated person would be expected to answer or know where to find the answer to questions that other staff members in the workplace may have.

There are different training options available, and it is the employer’s obligation to comply with this section and ensure that appropriate and complete training is provided.

Floor plans and drawings

Up to date plan location drawings must be submitted for proposed installation of a fixed X-ray source and when there are changes made to an existing fixed X-ray installation.

You don’t need to hire a third party to make your plan location drawings. The drawings must meet the requirements of the regulation. All requirements listed below must fit onto one page.

Accompanying plan location drawings must be compliant with subsection 6(4) of Regulation 861. Your plan location drawings must:

• have the name of the applicant and address of the X-ray source
• be legible and of a scale not less than 1:100 and suitable for microfilming
• indicate the direction north
• show the proposed location of the X-ray source and, if applicable, its range of motion
• show the proposed location of the X-ray control panel if it is in a different location than the X-ray source
• indicate the use of the rooms and areas that are beside, below and above the proposed location of the X-ray source
• indicate the type and thickness of any shielding that is installed or will be installed on the boundaries of the proposed location
• indicate the type and location of warning lights, interlocks, cut-off switches and any other safety devices

You can submit your plan location drawings electronically by email or in hard copy by mail. Email is preferred.

• Electronic drawings: submit a PDF file that is fully legible and to scale when printed on paper no larger than letter size (8 ½ inches by 11 inches).
• Hard copy drawings: the plans can be computer generated, hand drawn or copied from pre-existing drawings (such as construction blueprints). The plans must be legible, drawn to scale and in ink. Submit two copies when submitting by mail.

Figure 1: Sample plan drawing

This sample plan drawing complies with subsection 6(4) of Regulation 861. It shows the floor plan for a veterinary clinic with an X-ray source and includes:

• the name and address of the facility
• direction north
• scale
• dimensions of the room
• adjacent areas
• thickness of drywall, doors, the ceiling and the floor

The range of motion of the source is also shown.

File attachments

Select the “Add File” button to include your plan drawing. You may include additional information, such as the X-ray’s brochure, radiation shielding calculations, or any notes you wish to convey to the reviewers. Shielding calculations can be requested at RPS’ discretion during review of your X-ray submission.

Occupancy and use of surrounding areas

Occupancy factor is a percentage level for usage of the areas surrounding the X-ray room. For example, an office next to the X-ray room that is occupied 100% every workday will have an occupancy factor of 1. This is necessary for calculating radiation shielding requirements. An adjacent washroom that is not occupied 100% of the time would require less radiation shielding, and the default occupancy factor for a public washroom would be 0.05 as outlined in the form.

The form includes default occupancy factors as set out by Health Canada’s Safety Code 28, “Radiation Protection in Veterinary Medicine”.

Alternate occupancy factors (optional)

The default occupancy factors are listed to calculate the required radiation shielding, but you may submit alternate occupancy factors in this field.

Add another X-ray source (+)

If you are registering more than one X-ray source, you may select this button to add additional X-ray sources to your form. You will need to fill out all the above information, from “X-ray Source number” above and on for each additional X-ray source.

Attestation

Please complete this section and then save by selecting the “Save” button.