The present proposed regulation would limit both mammographic and diagnostic physicist working at one facility from surveying their own facility’s equipment. This is not the case in therapy. Therapy private inspectors are required to complete only one facility and one unit per year. This makes no sense. The mammographic requirements are three times that of the present Federal MQSA standard which only require 2 facilities in a 24 month period. Why the State would choose to supercede the federal requirements, is not clear. The requirements for diagnostic inspections seem unusually high, 10 facilities and 20 tubes. Why they need to exceed the requirements for mammography is unclear.

I would propose that the mammography requirements be aligned with those of the MQSA and that the diagnostic be similar to therapy in that they require 1 facility and 3 tubes in a 12 month period.

If passed in their present format, the regulations would severely impact on the ability of facilities to get required surveys done by placing unnecessary restriction on the physicist performing diagnostic surveys and undoubtably increase the cost to those facilities.