August 11, 2023
Michigan Department of Labor and Equal Opportunity
MIOSHA, Technical Services Division, Standards and
Freedom of Information Act Section
530 West Allegan Street
P.O. Box 30643
Lansing, MI 48909-8143
On behalf of The American Registry of Radiologic Technologists (ARRT), I appreciate
the opportunity to comment on the Ionizing Radiation Rules Governing the Use of
Radiation Machines.
As a national certification organization, ARRT develops and administers standards to
assess the qualifications of technologists who work in medical imaging and radiation
therapy. We provide credentials to more than 350,000 Registered Technologists
nationwide; approximately 11,000 of them live and work in Michigan. We were founded
in 1922 and operate as a nonprofit credentialing organization.
We respectfully recommend several changes to your document.
References to Medical X-Radiation
Consider changing references from “medical x-radiation technology” to “medical
radiologic technology” and references from “medical x-radiation technologist” to
“medical radiologic technologist.” Doing so will align Michigan’s terminology with
that of professional societies and national credentialing organizations.
Rule 333.5742 Credentialing Requirements (iv)—CCI – Registered
Cardiovascular Invasive Specialist (RCIS)
We recommend that anyone who maintains a RCIS certification also maintain a medical
radiography certification. The American Society of Radiologic Technologists (ASRT)
practice standards consider cardiac and interventional radiography to be postprimary
modalities. In other words, candidates must first earn a primary radiography certification
before they may pursue the postprimary RCIS credential. Therefore, all individuals
wishing to use the RCIS credential must meet the same minimum requirements that
people who hold ARRT Cardiovascular Interventional Radiography, Cardiac
Interventional Radiography, and Vascular Interventional Radiography credentials must
meet.
