Good afternoon. As President of the Ohio Society of Radiologic Technologists (OSRT), I offer the following comments on the proposed amendments to OAC Chapter 3701-72.

The Ohio Society of Radiologic Technologists is thankful to have the opportunity to submit comments relative to the proposed rule changes to 3701-72.

The OSRT is in support of the majority of the proposed changes and feels they are relevant and necessary to the to the safe practice of licensed personnel. The two areas of concern are:

1. 1. 3701-72-03 (C)(b)
   Individuals certified by the NMTCB prior to July 2019 did not have to meet the requirement mandated by this section. Therefore, under these proposed rules individuals who obtained the CT credential from NMTCB before that date may practice legally in Ohio without being in compliance with the criteria set forth in these rules. Although this number is not large, approx 1000 individuals nationally, they would essentially be granted a silent exemption from this rule as it is written. If the intent of this rule is to assure safe administration of radiation during these procedures, this exemption undermines that goal and allows for different criteria for different individuals.
   The OSRT would like to see this exemption from the rules removed.
   
   
2. 3701-72-04(K). The wording is unclear and could result in untrained individuals performing PET/CT and SPECT/CT. (K)Positron emission tomography-computed tomography and single photon emission computed tomography-computed tomography fusion procedures shall be performed by a licensed nuclear medicine technologist or a licensed radiographer who has obtained training and demonstrated competency with the equipment and procedures. Does the underlined content apply and modify the term licensed radiographer only or does the licensed nuclear medicine technologist need training and competency on the PET/CT equipment and procedures as well? It differs from the wording/format in the subsequent rule, 3701-72-04(L) and could create confusion. Comparing 3701-72-04(K) to 3701-72-04(L), it is clear in (L) that the training and competency requirement applies to both the radiographer and the radiation therapist. (L) RadiographersLicensed radiographers or licensed radiation therapists, who have obtained training and demonstrated competency with the computerized tomography (CT) equipment and CT protocols, may operate CT units for radiation therapy simulation procedures. 

The OSRT would be in support of clarifying this wording, perhaps by adding a comma in 3701-72-04(K) after licensed radiographer to match the grammatical format in 3701-72-04(L). The OSRT would like to thank the Ohio Department of Health for the opportunity to provide input into these important decisions.

Sincerely,

Julie Gill, Ph.D., R.T.(R)(QM)
President, OSRT