February 2024 Report

Georgia State Board of Veterinary Medicine Rules Committee – January 31, 2024  

Discussion – BR 700-12-.10 Radiology and the Veterinary Facility Inspection Form_rev 01-31-24 (attachment A)  

During the August 2023 meeting the Board requested the assistance of Dr. Riddick, Executive Director of Georgia Veterinary Medical Association (GVMA) to locate information regarding x-ray and/or radiology regulations and protocols from the Georgia Department of Community Health related to their Rule 111-8-90.01. At that meeting, the Board further charged the Rules Committee to review any information received and make recommendations to amend Board Rule 700-12-.10 Radiology and the Board’s Veterinary Facility Inspection Form if necessary.  

The Committee reviewed the Veterinary Facility Inspection Form that was amended according to the discussion the Rules Committee had during the January 25, 2024 meeting and consulted with Dr. Riddick about any additional information she received about the standards for the use of other radiological equipment in veterinary facilities. The most significant changes made to the form were to add the relevant Board Rule at the start of each section, incorporate the types of licenses and permits a facility may need to have on hand, more detail as to what an investigator should find in the facility pharmacy and drug log books, outlining items that may need to be on-hand in the facility crash cart as well as a more detailed description of the radiological equipment standards.  

The Committee requested Dr. Riddick’s input on the proposed changes. In response, she recommended that the Committee consider whether there should be a requirement that veterinarians submit proof of annual radiological equipment inspections at the time of renewal of their business license or professional licenses if the veterinarian owns the facility. She also suggested some consideration of requiring licensees to complete some CE or training in radiology safety as a renewal requirement. Dr. Riddick further informed the Committee that she had not yet received any information from the Georgia Department of Community Health (GDCH) concerning other types of radiological equipment.  

There was also some discussion as to whether the Board has the authority to conduct random inspections of veterinary facilities. Dr. Wright suggested adding a question to the renewal application as follows: “Do you own a practice that uses radiological equipment?” If the answer is yes, a current inspection form and proof of employee training for authorized users must be submitted.  

Ms. Price shared the information she collected on the standards for the use of other types of radiological equipment based on her review of checklists by the Joint Commission, other licensing boards, and the GDCH. She reported that the minimum requirements were very similar. Since veterinary practices may use other types of radiological equipment, it may benefit licensees to post a copy of the Board’s Veterinary Facility Inspection Form so that they know what the Investigators will be looking for when conducting an inspection. She stated it may also be helpful to add a definition on the facility inspection form of what the Board means by radiological equipment. The committee drafted a definition to add to the form.  

Ms. Price remarked that it is likely that the Board has the authority to require continuing education hours in radiology safety, the Board may not have the authority to add the renewal question concerning inspections or conduct random inspections. As a result, the Committee may wish to offer their suggestions to the Board and recommend that the Board obtain advice from the Attorney General’s Office surrounding the authority to implement what is suggested. She stated that since the Board has no authority to require proof of annual radiological equipment inspection and training at the renewal of the facility’s business license, the also may wish to recommend that the Board vote to refer that suggestion to the Corporation’s Division. Ms. Price further suggested that it may not be necessary to amend BR 700-12-.10 if licensees are put on notice of expectations through the publishing of the Veterinary Facility Inspection Form.  

It was determined that a Memorandum of Advice from the Attorney General’s Office is necessary before the Committee proposes any amendments to BR 700-12-.10 Radiology.  

The Committee recommends that the Board requests a Memorandum of Advice from the Attorney General’s Office as to whether the Board has the authority to perform random veterinary facility inspections without receiving a complaint. The Committee further recommends the Board seek Attorney General advice concerning the addition of the proposed radiology question on the renewal application as well as a requirement for proof of annual inspection and operator radiology safety training based on the licensee’s response.  

The Committee also recommends that the Board refer a request to GVMA to advocate for the Georgia Secretary of State Corporations Divisions to require proof of annual radiological equipment inspection and operator radiology safety training at the renewal of the veterinary facility license if the advice received requires a statutory change to the Georgia Veterinary Practice Act.  

The Committee recommends referring the Veterinary Facility Inspection Form as attached to the full Board for review during the February 7, 2024, WebEx meeting.  

Adjournment No further business was discussed, and the Committee meeting adjourned at 10:37 a.m.  

Georgia State Board of Veterinary Medicine Rules Committee – January 25, 2024 

Discussion – BR 700-12-.10 Radiology  

The Committee was charged to determine if BR 700-12-.10 and the Veterinary Facility Inspection Form should be amended to more accurately reflect the requirements outlined by the Georgia Department of Community Health (GDCH) in their Rule 111-8-90.01. In an attempt to gain more information about the GDCH requirements, the Board requested the assistance of Dr. Riddick, Executive Director of the Georgia Veterinary Medical Association (GVMA), to locate information regarding x-ray and/or radiology inspection protocols. It is the consensus of the Committee that employees who operate radiology equipment in veterinary facilities should be adequately trained and the safety of the machines monitored regularly as both are paramount to public protection and safety. When discussing the training that is currently available, it was revealed that currently, GVMA appears to be the only provider of radiology training in veterinary medicine.   

The Committee engaged in a conversation regarding the National Council on Radiation Protection and Measurements (NCPR) and the fundamentals of radiation shielding, and they determined a definition should be provided for both the Investigators and the facility owners. Since the Board Investigators often request a copy of five (5) random records, the veterinary inspection form could be amended to require 5 random sets of X-ray films. If the films show the entire animal, or if there is any human anatomy shown in the x-ray, that portion of the inspection is considered a failure.   

The Committee recommends that the X-ray machines be calibrated and that the reports be posted for the Investigator to review. The frequency of the calibrations was discussed, and it was recommended that the machines undergo a formal review a minimum of every five (5) years. Whereas the Committee determined that the frequency of calibration could pose a financial hardship to some facilities, including factoring in the mileage of the licensed or certified professional inspector, it is a necessary expense to ensure compliance with federal, state, and local requirements and such expense should be included in the facility’s budget.  

The Committee reviewed the radiology inspection checklist that was provided to Dr. Riddick by the GDCH. The Committee agreed that the same requirements in human medicine should be in place for veterinary medicine since human beings are operating the machinery and using it on animals. It was the consensus of the Committee that the requirements would apply at any veterinary facility as defined in O.C.G.A. § 43-50-3(31).  

The inspection checklist discussion for radiological equipment included proper collimation, timer accuracy, termination, and the exposure switch, filtration for the certification process of the x-ray machine, the control panel, personal protective equipment (PPE) integrity, and employee spacing from the machines during the x-ray process, shielding to include thyroid shields, a dosimetry badge, the darkroom, area cleanliness, radiological record keeping, and the machine warning label. PPE should be checked for integrity every six (6) months and the Investigator will ask for a copy of this documentation.  

Dr. Riddick asked the Committee if there should be any consideration given to the use of MRIs and CT scans. The Committee agreed that it should determine if the guidelines established for X-rays fit most all radiological equipment standards. Further discussion of amendments to Board Rule 700-12-.10 was tabled pending additional research on the standards of other forms of radiological equipment.  

Ms. Price will compose a finalized checklist to include items from the discussion, and Dr. Riddick will attempt to reach out to GDCH to obtain information about other radiological equipment. The Committee will hold a meeting on January 31, 2024, at 9:00 a.m. via WebEx to review the revised Veterinary Facility Inspection Form.  

Discussion – Acceptance of U.S. Department of Agriculture – Animal and Plant Health Inspection Service (USDA-APHIS) Accreditation Modules for LEAP Credit  

During the December 13, 2023, meeting, the Georgia State Board of Veterinary Medicine referred the correspondence regarding USDA- APHIS Accreditation Modules for LEAP Credit to the Rules Committee. The Committee determined that the USDA-APHIS modules deal with international and national regulations of animal movement, disease traceability, and disease control, and the instructors are established and verified. As a result, credit for LEAP CE should be awarded for the completion of the modules.   

The Committee reviewed several options for awarding LEAP (Legal, Ethical, and Professional) CE credit for the licensees who complete the USDA-APHIS modules. It was recommended that the veterinarians who provide proof of completion of three modules for Level 1 accreditation and the veterinary technicians who complete three modules, will receive one (1) hour LEAP CE credit. Those veterinarians who provide proof of completion of six modules for Level 2 accreditation, will receive two (2) hours of LEAP CE credit.  

The Committee discussed the rationales for their recommending amendments to Board Rules 700-7-.03 and 700-7-.04 to include the USDA-APHIS modules for LEAP credit. They determined that the modules provide education on regulations and animal disease control on an international and national level. The modules are certified by an entity that is federally approved and thoroughly vetted. Amending the existing rules will allow for more LEAP options for licensees. The policy purpose of the rule amendment is to facilitate access to LEAP CE programs and ensure compliance with federal regulations.  

The amendments will prohibit and prevent unsafe practices and/or fraud by providing educational access for self-knowledge and to better educate the licensees on the rules and laws that affect animal welfare which ensures competent practitioners. Additionally, the amendments provide more available LEAP CE program options than currently exist. The amendments carry out policy objectives that are expressed in a statute by guaranteeing practitioners have more options to fulfill their LEAP CE requirements outlined in the Board Rules. The program offerings help licensees to ensure that the State of Georgia remains free from infectious diseases by aligning the practices of licensees with federal regulations as it relates to the safe handling of infectious agents.   

The Committee considered multiple variations of the rule amendment and determined that the tiered approach to granting credit is fair and equitable for the different levels of training for the modules.  

Independent support for the rule amendment includes support from the Georgia Veterinary Medical Association (GVMA), practitioners, and constituent requests from stakeholders who have frequently requested additional LEAP CE program opportunities and rules from other jurisdictions, such as the State of Tennessee which offers credit for these courses and have similar LEAP CE requirements as the State of Georgia. Additionally, the USDA-APHIS programs align with ensuring national standards.  

The rule amendment will positively affect veterinarians and veterinarian technicians by allowing more access to LEAP CE courses to achieve renewal requirements more readily.  

The rule amendment will have a positive economic impact on businesses in Georgia as it reduces the amount of time and money licensees spend searching for LEAP CE courses elsewhere, which equates to decreased time away from work and travel expenditures and allows providers who were already completing the modules to utilize them toward meeting state LEAP requirements, thus decreasing the need to pay for additional courses.  

The Committee recommended to refer to Board Rule 700-7-.03 Continuing Veterinary Education and Board Rule 700-7-.04 Veterinary Technician Continuing Education to the full Board to review their rule amendments during the February 7, 2024, WebEx meeting. (Attachments A and B)   

Adjournment No further business was discussed, and the Committee meeting adjourned at 11:28 a.m.