1.2 Pregunta de Investigación
1.3.2 Estrategias de afrontamiento
21 CFR 900.12(e)(9)
Surveys.
(i) At least once a year, each facility shall undergo a survey by a medical physicist or by an individual under the direct supervision of a medical physicist. At a minimum, this survey shall include the performance of tests to ensure that the facility meets the quality assurance
requirements of the annual tests described in paragraphs (e)(5) and (e)(6) of this section and the weekly phantom image quality test described in paragraph (e)(2) of this section.
(ii) The results of all tests conducted by the facility in accordance with paragraphs (e)(1) through (e)(7) of this section, as well as written documentation of any corrective actions taken and their results, shall be evaluated for adequacy by the medical physicist performing the survey.
(iii) The medical physicist shall prepare a survey report that includes a summary of this review and
recommendations for necessary improvements.
(iv) The survey report shall be sent to the facility within 30 days of the date of the survey.
(v) The survey report shall be dated and signed by the medical physicist performing or supervising
the survey. If the survey was performed entirely or in part by another individual under the direct supervision of the medical physicist, that individual and the part of the survey that individual performed shall also be identified in the survey report.
Question: What are the requirements of the annual survey?
Answer: Once a year, each facility must be surveyed by a medical physicist or by someone in training
under his or her direct supervision. The survey will include:
(1) performance of the annual tests described in the regulations (Table 2 above and the QC tests for other modalities, if applicable) and the weekly phantom image quality test;
(2) review of the results of the QC tests conducted by the facility (Table 1 above), as well as of written documentation of any corrective actions taken and their results; and
(3) a report, which must be provided to the facility within 30 days of the date of the survey, that includes a summary of the areas tested and reviewed and recommendations for necessary
improvements.
The annual tests must be performed using technique factors and test conditions as stated in the regulations whenever those factors are specified. Otherwise, technique factors that are clinically used in the facility for which the annual survey is conducted should be used whenever possible. For test procedures that determine dose to the average breast, the same kVp value (within +/- 1 kVp of that used clinically for the average breast) must be used for measuring both the entrance skin exposure and the HVL.
The report must be dated and signed by (or contain the identification of) the medical physicist performing or supervising the survey and any other individual who performed or assisted in the survey. If the survey is done over a period of time, the dates of completion of the individual parts must be indicated in the report.
21 CFR 900.12(e)(10)
Mammography equipment evaluations. Additional evaluations of mammography units or image processors shall be conducted whenever a new unit or processor is installed, a unit or processor is disassembled and reassembled at the same or a new location, or major components of a
mammography unit or processor equipment are changed or repaired. These evaluations shall be used to determine whether the new or changed equipment meets the requirements of applicable standards in paragraphs (b) and (e) of this section. All problems shall be corrected before the new or changed equipment is put into service for examinations or film processing. The mammography equipment evaluation shall be performed by a medical physicist or by an individual under the direct supervision of a medical physicist.
Question: When are “additional mammography equipment evaluations” required and who must
conduct the evaluations?
Answer: Whenever a new unit or processor is installed, disassembled and reassembled at the same or
a new location, or major components are changed or repaired, an evaluation of the mammography unit or image processor is required. The medical physicist should decide which tests need to be performed following a particular repair, and should explain the rationale behind his or her decision. Examples of major changes or repairs that would call for equipment evaluations are: replacement of an x-ray tube, collimator, AEC unit, AEC sensor, or x-ray filter. For the processor, a total overhaul would be an example of a major repair. Routine preventive maintenance, pump replacement,
replacement of the developer or fixer racks, replacement of the control board or changes in chemistry brand are not examples of major changes or repairs and would not require evaluation by a medical physicist.
This additional evaluation is needed to verify that all functions that may have been affected by the change or repair have been successfully restored even if a full survey had recently been completed. For a new unit, an equipment evaluation is needed before the unit is used on patients unless the unit has already undergone a full survey. In this situation, the facility must follow the accreditation body procedures. Keep in mind that under MQSA, the facility has the ultimate responsibility for ensuring image quality and patient safety. If changes or repairs to the system are anticipated, contact the facility’s accreditation body to inquire whether the change affects a major component and requires an evaluation.
The equipment evaluation must be performed by a qualified medical physicist or by an individual under the direct supervision of the medical physicist.
These evaluations will be used to determine whether the new or changed equipment meets the
requirements of applicable standards in 900.12(b) and (e). All problems shall be corrected before the new or changed equipment is put into service for examinations or film processing. A facility should maintain documentation that shows the date(s) on which a mammography equipment evaluation was performed, who performed the evaluation, and that any identified problems were corrected before the equipment was used on patients. A facility must maintain this documentation until the next inspection that verifies compliance.
21 CFR 900.12(e)(11)
(i) The facility shall establish and implement adequate protocols for maintaining darkroom, screen, and view box cleanliness.
(ii) The facility shall document that all cleaning procedures are performed at the frequencies
specified in the protocols.
Question: What facility cleanliness measures are required under MQSA and what constitutes
acceptable documentation of such measures?
Answer: MQSA does not specify cleanliness measures. However, the facility must establish and
follow adequate protocols (such as those found in the latest ACR Mammography QC Manual) for darkroom, screen, and view box cleanliness. Acceptable documentation would be written procedures for performing the corresponding cleaning activities, with records showing that each was conducted at the designated frequency, and was followed by the appropriate corrective actions when needed.
21 CFR 900.12(e)(13)
Infection control. Facilities shall establish and comply with a system specifying procedures to be followed by the facility for cleaning and disinfecting mammography equipment after contact with blood or other potentially infectious materials. This system shall specify the methods for
documenting facility compliance with the infection control procedures established and shall:
(i) Comply with all applicable Federal, State, and local regulations pertaining to infection control;
and
(ii) Comply with the manufacturer's recommended procedures for the cleaning and disinfection of the
mammography equipment used in the facility; or
(iii) If adequate manufacturer's recommendations are not available, comply with generally accepted
guidance on infection control, until such recommendations become available.
Question: What infection control procedures are required under MQSA ?
Answer: Facilities must establish and follow a protocol for cleaning and disinfecting mammography
equipment that has come in contact with blood or other body fluids or potentially infectious materials. MQSA inspectors will be looking for such a protocol or procedure that the facility is following. A sign- off sheet recording cleaning after each patient is not required. For additional guidance on this, refer to OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030), any additional State and local regulations on this subject that may be applicable to the facility, and manufacturer's procedures specific to their equipment.