OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

April 3, 2009

Lynne H. Slim
5168 Holly Springs Dr
Douglasville, GA  30135-4953

Dear Ms. Slim:

Thank you for your letter, February 28, 2009, to the Occupational Safety and Health Administration (OSHA).  Your letter was forwarded to OSHA's Directorate of Enforcement Programs for a response.  As a dental hygienist, you said that you are concerned that there are no guidelines on the radiation hazards when taking digital dental radiographs.  You also said that some dental professionals using digital radiography equipment are taking fewer safety precautions because they think very little radiation is emitted from the x-ray tube.  

Generally, digital radiography does significantly reduce the amounts of ionizing radiation to which employees or patients may be exposed during diagnostic testing.  This advance in technology is an example of an improved engineering control that OSHA advocates.  Digital radiography has been developed for dentistry and many other applications, and reduced radiation is only one of the many advantages it provides over conventional (analog) radiography.  However, OSHA agrees with you that employers should continue to use additional engineering and work practice controls, administrative controls, and protective equipment, as necessary to maintain radiation exposures as low as reasonably achievable (ALARA), which is the widely-recognized goal for all radiation protection programs.  For OSHA compliance, employers using digital radiography systems must also continue to comply with the OSHA standard on ionizing radiation, 29 CFR 1910.1096.  If you have a specific complaint about your workplace, you may contact our area office nearest you:

Atlanta West OSHA Area Office
2400 Herodian Way, Suite 250
Smyrna, GA 30080
Ph: 770-984-8700, Fax: 770-984-9031

We thank you for your interest in occupational safety and health.  We hope you find this information helpful.  If you have any further questions, you can consult OSHA's website at http://www.osha.gov, or you may contact the OSHA Office of Health Enforcement at (202) 693-2190.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs

cc:  Atlanta Regional Office