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							              MQSA Archived Document

 Although some of the information in this document has
 been modified or no longer applies to MQSA regulatory
requirements, this item is presented here for research and
                   historical reference.
                          From FDA/CDRH to help facilities implement MQSA




                           Summer 1998                                          Volume 5, Issue 3




                                         Final MQSA Rule, Part 3
                                                 ith less than a year before the      rule: breast implant imaging, con-
                                                 final Mammography Quality             sumer complaints, and additional
                                                 Standards Act (MQSA) rule            mammography review and patient
                                         takes effect on April 28, 1999, facilities   notification.
     fter serving four and a half        should review their personnel opera-
     years as Director of FDA’s          tions, equipment, and procedures for
     Division of Mammography             regulatory compliance. Early prepara-        MQSA requires that specific atten-
Quality and Radiation Programs           tion is critical, especially in areas that   tion be given to ensuring that
(DMQRP), Florence Houn,                  may require weeks or months of lead          patients with breast implants receive
M.D., is moving on to become             time to correct problems.                    adequate examinations. This was not
Deputy Director of the Office of                A checklist of key areas for facili-   addressed in either the ACR accredi-
Drug Evaluation II in FDA’s              ties to review is included in this issue     tation program or the interim regula-
Center for Drug Evaluation and           (see page 6). The two previous issues of     tions, but has now been included in
Research. (See “From the Direc-          Mammography Matters covered some             the final regs. The purpose is to
tor” column in this issue.) John         of these major items in more detail.         ensure that the estimated 2 million
McCrohan, DMQRP Deputy                   Areas covered included personnel             women with breast implants can
Director, succeeds Dr. Houn as           requirements for interpreting physi-         benefit from mammography services.
Director.                                cians, radiologic technologists, and              The final rule requires facilities
     Trained as a medical physicist      medical physicists; some of the new          to inquire about the presence of
with a master’s degree in Radio-         equipment standards; reporting and           implants before the examination, and
logical Sciences from the Univer-        recordkeeping; and quality assurance.
sity of Washington, McCrohan                   Readers should note that back                              Continued on page 5

has been an officer in the Public         issues of Mammography Matters are
Health Service (PHS) since 1974,         available on the Internet (see                 What’s Inside
serving in FDA’s Bureau of Radi-         www.fda.gov/cdrh/dmqrp.html). In
ological Health and its successor        addition, FDA is preparing draft              From the Director                 2
organization, the Center for             guidance for implementing the final            A Big Step Forward on
                                         rule. Expected to be available for            Collimation Issue                 3
Devices and Radiological Health.
                                         public review and comment July                MQSA Advisory
McCrohan currently holds the                                                           Committee Update                  4
rank of Captain in the PHS.              1998, the first installment of this            MQSA Compliance Checklist         6
     In the mid-1970s, McCrohan          guidance will provide further clarifi-         On the Go: Mobile
was involved in the Breast Expo-         cation on various questions raised            Units and MQSA                    8
sure: Nationwide Trends (BENT)           since the final rule was published in          Q&A                              10
program. His involvement in              October 1997.                                 FDA Accepts Three
                                               This issue touches on some of           More Training Courses            11
                 Continued on page 5
                                         the new areas covered in the final             Address Change Reminder          11
From the Director . . .
    Replacing Florence Houn as DMQRP                                                          important procedure. As a nation, we
    Director offers me the opportunity to                                                     have defined a common set of standards
    personally acknowledge her years of ser-                                                  for providing safe, reliable mammogra-
    vice to improving the health of America’s                                                 phy. By applying these standards consis-
    women and to recall some of the pro-                                                      tently through a quality inspection pro-
    gram’s accomplishments under her                                                          gram, in partnership with the facilities,
    tenure. She is a valued and trusted col-                                                  we have significantly improved the pro-
    league, whose determination to improve                                                    portion of facilities delivering quality
    the quality of mammography con-                                                           mammography services that can provide
    tributed to the program’s documented                                                      life-saving diagnostic information in
    success. I’m proud to continue efforts put                                                combating breast cancer.
    in place under Dr. Houn’s leadership                                                            There are many challenges before us,
    now that she’s moving on to meet new                                                      such as developing appropriate guidance,
    challenges at FDA’s Center for Drug                                                       as we prepare to implement final regula-
    Evaluation and Research.                                                                  tions next year. Facilities should keep alert
          As some of you may know, in addi-          28, 1999. The final rule was devel-       for notices regarding the availability of
    tion to serving as the DMQRP Director            oped with the advice of the National     proposed guidance sometime this summer.
    for the past four and a half years, Dr.          Mammography Quality Assurance            The public will have a 90-day comment
    Houn is an oncology instructor at Johns          Advisory Committee, composed of          period after guidance is published in the
    Hopkins School of Medicine. As Co-               consumer and medical representa-         Federal Register.
    Director of Johns Hopkins’ breast sur-           tives, and took into consideration             We’re also developing new inspec-
    veillance service, she sees women at high        public comments from approximately       tion procedures tied to the final rule, as
    risk for breast and ovarian cancer and           1,900 respondents to FDA’s proposed      well as the new States-as-Certifiers
    counsels them on early detection and             regulations published April 3, 1996.     demonstration project as provided for by
    prevention as well as risk management        •   Accreditation and certification of        MQSA (see Spring 1998 Mammogra-
    options. Dr. Houn is a champion in the           10,161 mammography facilities as of      phy Matters, page 3).
    fight against breast cancer.                      December 31, 1997.                             I look forward to continuing our
          During Dr. Houn’s tenure as            •   Establishment of an outreach pro-        strong partnership with facilities, estab-
    DMQRP Director, FDA has accom-                   gram to help facilities meet the regu-   lished under Dr. Houn’s leadership, in
    plished the following:                           lations.                                 our mission to further improve the qual-
                                                 •   Establishment of an inspection pro-      ity of mammography in the United
    • Publication of interim regulations             gram in partnership with the states.     States.
      on December 21, 1993, to provide a         •   Establishment of a compliance pro-
      mechanism for accreditation and                gram to ensure that FDA regulatory
      certification of mammography facili-            requirements are adhered to, with an
      ties by October 1, 1994.                       emphasis on assisting facilities in
    • Publication on October 28, 1997,               meeting the regulations.
      of more comprehensive final regula-                                                      John L. McCrohan, M.S.
      tions, which become effective April            More important than the program-         Director, Division of Mammography
                                                 matic accomplishments is the success in         Quality and Radiation Programs
                                                 enhancing the quality of mammography
                                                 without adversely affecting access to this




2         Mammography Matters, Summer 1998
                                        A Big Step Forward on
             Summer 1998
                                        Collimation Issue
                                            he Spring 1998 issue of Mam-          have x-ray fields that extend beyond
Mammography Matters is a quarterly           mography Matters noted that a        the edges of the image receptor up to
publication of the Division of Mam-          conflict had been discovered          a specified limit. To obtain approval
mography Quality and Radiation
Programs (DMQRP), Center for            between the final MQSA regulations         of this alternative, which was granted
Devices and Radiological Health         and the Electronic Product Radiation      under section 900.18 of the MQSA
(CDRH), Food and Drug Adminis-          Control (EPRC) performance stan-          regulations, GE provided data for
tration. Its purpose is to help mam-    dards that must be met by mammog-         FDA review to show that their alter-
mography facilities comply with the     raphy equipment manufacturers.            native provides as great or greater
requirements of the Mammography         The conflict related to x-ray field and     assurance of mammography quality
Quality Standards Act of 1992. It is
distributed to mammography facili-      image receptor alignment. FDA is          as the original standard.
ties and other interested organiza-     pleased to announce an interim mea-            The approved alternative applies
tions and individuals.                  sure that will eliminate this conflict     to all GE Senographe mammography
    Articles may be reproduced or       for many facilities.                      systems, including those having
adapted for other publications.              The final MQSA regulations            model names 500, 600T, 800T, and
Comments should be addressed to:        require beam limiting devices to          DMR, and means that these systems
  Mammography Matters                   allow the x-ray beam to extend to or      will not have to be modified to be in
  FDA/CDRH (HFZ-240)                    beyond the non-chest wall edges of        compliance with the x-ray field-
  1350 Piccard Drive
                                        the image receptor. To be certain to      image receptor alignment require-
  Rockville, MD 20850
                                        be in compliance with the EPRC            ments of the final MQSA regula-
  Fax 301-594-3306                      requirement, some manufacturers           tions. The alternative becomes
Back issues of Mammography Mat-         have designed their units so that the     effective on April 28, 1999, the effec-
ters may be viewed on the Internet at   x-ray field does not extend beyond         tive date of the final MQSA regula-
www.fda.gov/cdrh/ dmqrp.html
                                        the edges of the image receptor. Such     tions. No time limit has been placed
John L. McCrohan, M.S., Director,       units would not be in compliance          on the period of approval.
DMQRP, CDRH                             with the final MQSA requirements.               FDA expects to achieve a general
Carole Sierka, Editor; Chief,                FDA previously advised facilities    resolution of this issue before April
Outreach Staff, DMQRP, CDRH
                                        to not change their equipment’s colli-    28, 1999. In the meantime, facilities
David Heffernan, Managing Editor        mation until this issue was resolved      with concerns about meeting the
Evelyn Wandell, Production              and it was clear what action, if any,     final MQSA alignment requirement
Manager                                 would need to be taken. Recently, the     and whose units are not covered by
Other contributors: Cathy Akey,         agency approved an application from       the approved alternative have the
Anne Bowen, Roger Burkhart,             the General Electric (GE) Company         option of encouraging the manufac-
Mary Cerny, Mike Divine
                                        for an alternative standard to the final   turers of their units to apply for simi-
                                        MQSA regulations. This alternative        lar alternative standards.
                                        will permit, but not require, units to
       Facility Hotline
   Call the facility telephone
   hotline (1-800-838-7715)
  for more information about
      FDA certification or
           inspections.




                                                                         Mammography Matters, Summer 1998               3
MQSA Advisory Committee Update
     he National Mammography                  Spring 1998 Mammography Matters,               and interventional mammography.
     Quality Assurance Advisory               page 4.)                                       With respect to interventional mam-
     Committee, which advises FDA                  “Our recommendation was to                mography, the committee will be
on a range of issues related to imple-        amend both sets of regulations to              looking at whether regulation is
menting MQSA, met in early May                avoid having many facilities modify            needed or whether similar results can
under the leadership of its new chair,        their equipment at great expense,”             be achieved through non-regulatory
Dr. Barbara Monsees, Chief of the             said Monsees. FDA expects to resolve           means, including voluntary accredita-
Breast Imaging Section at the                 this issue before the April 28, 1999,          tion.
Mallinckrodt Institute of Radiology.          effective date of the final MQSA reg-                At any given time, the committee
     One of the key issues discussed          ulations. In the meantime, FDA                 has between 13 and 19 members, who
at the May meeting was collimation            recently approved an alternative stan-         are invited to serve for overlapping
of the x-ray field. The MQSA regu-             dard to the final regulations that will         terms of up to four years. Members
lations regarding collimation are in          eliminate this conflict for many facili-        are drawn from among physicians,
conflict with the Electronic Product           ties. (See “A Big Step Forward on              medical physicists, radiologic technol-
Radiation Control (EPRC) perfor-              Collimation Issue,” page 3.)                   ogists, and other health professionals
mance standards that mammography                   The committee also reviewed               with significant experience in mam-
equipment manufacturers must meet             proposed inspection procedures                 mography. At least four members
under a 1968 law. (See “Facilities            under the final regulations and in the          come from national breast cancer or
Advised To Delay Collimation                  future plans to take up further dis-           consumer health organizations with
Changes Until Further Work,”                  cussions on digital mammography                expertise in mammography.




    Barbara Monsees, M.D.           Ellen Mendelson, M.D.          Patricia Wilson, R.T.             Carolyn Brown-Davis
    Chief, Breast Imaging Section   Chief, Women’s Imaging         Chief Technologist                Executive Director
    Mallinckrodt Institute of       The Western Pennsylvania       Biltmore Imaging Center           Breast Cancer Resource
      Radiology                        Hospital                                                         Committee
                                                                   Roland Fletcher, M.S.
    Department of Radiology         Department of Radiology
                                                                   Manager-Radiological Health       Kendra McCarthy, M.A.
    Peter Dempsey, M.D.             Michael Mobley, M.S.,            Program-ARMA                    Director, Administration for
    Director of Outpatient             M.P.A.                      Maryland Department of the           State of Virginia
       Radiology                    Director-Division of             Environment                     Department of Mental Health
    University of Alabama              Radiological Health
                                                                   David Winchester, M.D.            Robert Nishikawa, Ph.D.
                                    State of Tennessee
    Laura Moore-Farrell, M.D.                                      Professor and Chairman, Dept.     Assistant Professor of Radiology
    Director of Breast Imaging      Sandra Nichols, M.D.              of Surgery                     Department of Radiology
    Holt-Crock Clinic               Director Arkansas Department   Evanston Hospital                 The University of Chicago
                                       of Health
    Patricia Hawkins, M.P.H.                                       Kambiz Dowlat, M.D.               Ivis Febus-Sampayo
    Eldercare Consultant            Robert Pizzutiello, M.S.       Associate Professor of Surgery    Coordinator-Latina Project of
    Oklahoma State                  President-Upstate Medical      Rush-Presbyterian-St. Lukes          SHARE
    Department of Health               Physics, Inc.                  Medical Center
    Eldercare Services                                             Department of Surgery
                                    Edward Sickles, M.D.
                                    Professor of Radiology
                                    UCSF Medical Center
                                    Department of Radiology



4          Mammography Matters, Summer 1998
Final MQSA Rule                            collecting and resolving consumer
Continued from page 1                      complaints.                                  McCrohan
                                                FDA recognizes that facilities can      Succeeds Houn
to select views that will maximize         effectively address most consumer            Continued from page 1
visualization of breast tissue.            complaints. In the final rule, only
                                                                                        mammography continued with
     Related to this section is an addi-   serious complaints (as defined previ-
                                                                                        the Nationwide Evaluation of
tional requirement in the personnel        ously) that cannot be resolved by
                                                                                        X-ray Trends (NEXT) program
section specifying that all technolo-      facility staff are referred to the accred-
                                                                                        that assessed the practice of mam-
gists who begin performing mam-            itation body (and eventually to FDA).
                                                                                        mography in 1985, 1988, and
mography after April 28, 1999, must             Facilities should keep consumer
                                                                                        1992. He has also served on
have training in performing mam-           complaint records as part of their
                                                                                        numerous committees related to
mography on patients with breast           patient recordkeeping and should
                                                                                        mammography under the aus-
implants.                                  handle consumer complaint records
                                                                                        pices of the American College of
                                           with the same care as other records.
                                                                                        Radiology, the Conference of
                                                                                        Radiation Control Program
Another new area of regulation                                                          Directors, and the National
requires each facility to establish a                                                   Council on Radiation Protection
system for resolving serious consumer      The last new requirement in the              and Measurements.
complaints related to mammography          facility quality standards section                In 1997, McCrohan received
services. A “serious complaint” is         addresses additional mammography             the prestigious Stanley J. Kissel,
defined as a report of a serious            review and patient notification. For          Jr. Award as PHS’s Health Ser-
adverse event that significantly com-       cases in which FDA believes that             vice Officer of the Year.
promises clinical outcomes, such as        mammography quality has been                      “Under Dr. Houn’s leader-
poor image quality or a failure to         compromised, facilities must provide         ship, DMQRP helped improve
communicate results. (Please refer to      clinical images and other relevant           the quality of mammography in
pages 55977-55978 of the final regu-        information for review by an accredi-        the United States,” said McCro-
lations for definitions of “adverse         tation body. This additional review          han. “Her drive and determina-
event,” “consumer,” and “serious           will help FDA determine if serious           tion in building DMQRP helped
adverse event.”)                           conditions exist at a facility that          set a standard of documented
      The complaint system provides        would endanger public health such            success of which we’re all very
patients and their representatives with    that notification of patients and their       proud. As Dr. Houn moves on
a mechanism to report what they            referring health providers is needed.        to new challenges, I look forward
believe to be seriously deficient mam-           Facilities should note that FDA         to continuing DMQRP’s part-
mography services, and gives them the      views patient notification as an infre-       nership with facilities in the mis-
opportunity to have their complaints       quently used, cooperative action —           sion of improving mammogra-
heard, investigated, and resolved.         not a first-line step — reserved for          phy, particularly as we prepare
      The interim regulations required     severe public health risks.                  for implementing final MQSA
facilities to post an address where com-        For example, patient notification        regulations next year.”
plaints could be registered with the       may be warranted in cases where
accreditation body and to maintain         diagnoses of possible malignancy
records of all complaints. The final        may have been missed due to grossly
rule takes this requirement further to     inadequate performance. Patients,
require the development of a com-          their designees, health care profes-
plaint mechanism. This means that          sionals, or the public may have to be
each facility must establish its own       notified so that they may take appro-
written and documented system for          priate action.


                                                                              Mammography Matters, Summer 1998                5
6   Mammography Matters, Summer 1998
Mammography Matters, Summer 1998   7
On the Go:
Mobile Units and MQSA
    s facilities become more familiar     were owned by other entities such as     where the mobile unit “parks,” such
    with the final MQSA regula-            the government or a corporation. An      as a small hospital that has a radiol-
    tions, there may be many ques-        additional 17 percent of the units       ogy department and x-ray machines
tions regarding mobile mammogra-          were leased or owned by more than        but doesn’t have a mammography
phy units. What’s unique about            one group or organization.               unit. In this scenario, the mobile unit
operating a mobile unit? How does               The day-to-day operation of        provides the technologist who per-
the final rule affect the operation of     mobile mammography units can             forms the mammography examina-
mobile units? Does the rule require       vary considerably. In the most com-      tions, while the hospital staff does
anything that is specific to mobile        mon setting, the mobile unit, which      patient intake and film processing
units? If so, do the regulations pro-     is based at a central site, travels to   and provides the interpreting physi-
vide guidance as to how these             one or more satellite sites, where the   cian. Thus, both the mobile unit and
requirements should be met? Where         technologist takes mammograms.           stationary site serve as “partial
can operators of mobile units go for      The central site processes the mam-      providers” of mammography services.
more information?                         mographic films, sometimes several
    Articles in this and the next issue   days later. In this case, all films are   Filling a gap: Increasing access
of Mammography Matters focus on           put in a “black bag,” which shuts out    through mobile units
the operation of mobile units under       light; films are kept in the bag until    One primary goal of mobile mam-
MQSA, with some specific and               processing. This is referred to as                       mography is to
unique examples.                          batch processing. In                                     increase access to
                                          this scenario, the cen-                                  screening for breast
Mobile units defined                       tral site keeps, at the                                  cancer, especially
MQSA defines “facility” as any set-        very least, the units’                                   among underserved,
ting or entity, including a mobile        quality assurance/qual-                                  uninsured, and under-
mammography unit, that performs           ity control (QA/QC)                                      insured women and
any of the following mammography-         records.                                                 women in rural loca-
related activities: operates equipment         In contrast, a                                      tions. Mobile units
to produce a mammogram, processes         mobile unit may func-                                    strive to achieve this
mammograms, provides the initial          tion as a self-contained                                 goal through a variety
interpretation of mammograms,             operation; that is, the                                  of strategies. For
and/or maintains viewing conditions       technologist takes the                                   example, mobile units
for interpretation of mammograms.         mammograms, processes the films,          usually provide lower cost exams and
     An estimated 380 mobile mam-         and keeps the records. Thus, process-    accept a higher number of self-
mography units operate in the             ing is done “on board.” In a third,      referred patients than stationary or
United States. A survey conducted by      less common scenario, each examina-      hospital-based units. Mobile units
the American College of Radiology         tion site — whether a central or a       also increase availability of screening
(ACR) and the Centers for Disease         satellite site — processes all of its    by going to places where women are
Control and Prevention (CDC)              own films and keeps all of its own        — work sites, health clinics, commu-
found that 46 percent of mobile units     records.                                 nity centers, health fairs, shopping
were owned by hospitals, 20 percent             In more complex settings, mam-     malls and centers, places of worship,
were owned by radiologists or radio-      mography-related activities are split    retirement homes and centers, and
logic technologists, and 17 percent       between the mobile unit and the site     city streets.


8       Mammography Matters, Summer 1998
     The ACR/CDC survey found                  Perhaps the greatest challenge       verify the performance of each unit
that two-thirds of mobile units per-      associated with mobile mammogra-          to ensure that it produces adequate
formed only screening mammogra-           phy, however, is controlling the inter-   quality images. The final rule does
phy, with nearly all of the remaining     nal environment, especially in the        not specify which test or tests to use
units performing both screening and       face of extremes and/or changes in        to verify performance and leaves this
diagnostic mammography. The               climate. Maintaining ambient tem-         decision to the unit’s operator. How-
mobile units in this survey operated      perature, humidity, and ventilation is    ever, FDA will be issuing guidance
at a high volume, performing an           critical to producing high-quality        describing some acceptable methods.
average of 20 mammograms per day.         images consistently. Processing and       This change from the interim MQSA
                                          other equipment used in mammogra-         rule was made in response to reports
Special challenges                        phy-related activities are very sensi-    from mobile operators that moving
Providing mobile mammography ser-         tive to environmental changes.            the location of their unit(s) some-
vices is distinct in many ways from       Because of this sensitivity, some         times caused problems in the quality
that in stationary facilities. Mobile     equipment is incompatible with            of the mammograms produced.
unit operators and staff face a variety   mobile mammography, and equip-
of issues that are of little or no con-   ment that is onboard must be moni-        Meeting the new requirement:
cern to those running non-mobile          tored more frequently (and adjusted       Inspection and certification
units. Some of these issues include:      accordingly) than units at fixed sites.    Mobile units follow the same guid-
following local parking and related       Such issues form the basis for the        ance as stationary facilities in meeting
regulations, patients follow up,          additional equipment checks               requirements for inspection and cer-
onboard or batch film processing           required of mobile units under the        tification, with the additional equip-
(with associated unique quality con-      final MQSA regulations.                    ment QC checks for mobile units, as
trol problems), availability of equip-                                              described above. Inspections of
ment compatible with the mobile set-      What’s new under the final                 mobile units do often require extra
ting, environment and changes in          MQSA rule                                 time and effort, however, and usually
seasons and weather, and sometimes        Prior to implementation of MQSA,          must be scheduled well in advance,
very limited space for record storage.    the ACR had a voluntary program           requiring a high level of coordination
     Processing is a significant issue     for accrediting each mammography          among staff and inspectors.
for mobile units. For example, with       unit. Under MQSA, the FDA con-                 Most complex are situations
onboard processing, technologists         ducts inspections and provides for        where mammography activities are
can check the quality of the images       certification of all mammography           split between the mobile unit and
produced onsite and obtain supple-        facilities, including mobile units.       another group or facility. Often,
mental views at the time of the initial        MQSA states that requirements        explains FDA’s Mike Divine, who
exam. Onboard processing also can         under the rule are universal to all       specializes in MQSA compliance
reduce patient recalls and eliminate      units, whether fixed or mobile. Thus,      issues, the mobile units are the only
latent image fading, which can occur      for all intents and purposes, mobile      certified mammography facility and,
with batch processing when films are       units must meet the same criteria and     as such, are legally responsible for all
not processed for some time. On           the same standards as fixed units. In      mammography-related functions.
the other hand, units that do             addition, after the final regulations      Sometimes, the non-mobile site, such
onboard processing have specific           become effective on April 28, 1999,       as a small hospital without mammog-
space requirements and must accom-        equipment checks must be per-             raphy radiology equipment, certifies
modate for mixing, spillage, and dis-     formed on mobile units every time         jointly with the mobile unit. In yet
posal of chemicals. These and other       the unit is moved and before any          another scenario, both the mobile
factors contribute to the added           patient examination is done. Under        unit and its “partner” site are certified.
expense of running a unit with            this new quality assurance directive, a
onboard processing.                       mobile unit operator is required to                            Continued on page 11



                                                                           Mammography Matters, Summer 1998                9
Q&A
 Q & A is a regular column in
 Mammography Matters. We wel-              Q         Does FDA plan to distrib-      A         Mammographic modality
 come your questions and will publish             ute a poster or notice for               is defined as a technology
 answers to any that are of general          facilities to display that informs        used for radiography of the
 interest. Send your questions to          patients with serious complaints,        breast, which falls under MQSA
 Mammography Matters,                      that cannot be resolved by the           authority. Since MQSA authority is
 FDA/CDRH (HFZ- 240), 1350                 facility, about how to report those      limited to imaging with x-rays, MRI
 Piccard Drive, Rockville, MD              problems? If not, should facilities      and ultrasound are not included;
 20850, Fax 301-594-3306.                      provide such notices?                therefore personnel who use those
                                                                                    modalities do not have to have
                                            A        No. Although the final          training with them in order to meet
                                                   regulations provide a com-       MQSA requirements.
     Q    I submitted a question to            plaint mechanism, there is no
       FDA requesting clarification         requirement for facilities to post a
   of a point under the final regula-       sign or notice with instructions         Q       Since hardly anyone works
 tions but have not received an            about registering consumer com-                with xeromammography any
 answer yet. In the past FDA has           plaints. However, as a public ser-         more and MRI and ultrasound
 responded quickly to my ques-             vice, facilities may wish to do so.      are exempt, doesn’t this really
 tions. Why haven’t I heard any-           Complaints that cannot be                mean that, at present, most per-
     thing yet?                            resolved at the facility should be       sonnel only have to have training
                                           forwarded to the facility’s accredi-         with screen-film systems?
     A       Please be patient. Your       tation body. Facilities should pro-
                                                                                    A          That’s right. This further
         question concerns an area in      vide consumers with instructions
     which guidance is currently being     for filing complaints with the facil-            means that the specific
 developed. Before the guidance is         ity accreditation body. Also, the           mammographic modality train-
 implemented, facilities will have a       name and address of the accredita-       ing requirement will automatically
 90-day period to review and submit        tion body is listed on each facility’s   be met while meeting the general
 comments regarding the proposed           certificate, which must be promi-         initial training requirement. It will
 guidance. The notice of the avail-        nently displayed.                        also be met for the continuing
 ability of the proposed guidance will                                              education requirement as long as 6
 be published in the Federal Register                                               of 15 hours is with screen-film
 this summer, and the document             Q        The final regulations            systems. But should another mam-
 itself will be available on the website         require training in each           mographic modality become
 (http://www.fda.gov/cdrh/dmqrp.             mammographic modality used             accepted in the future (digital
 html) and by mail. Submit your            by a physician, technologist, or         mammography seems the most
 request by fax to 301-986-8015 or         physicist. Would you please clarify      likely candidate), personnel will
 by mail to MQSA, c/o SciComm,             what is meant by mammographic            have to receive additional training
        .O.
 Inc., P Box 30224, Bethesda,              modality? Only screen-film and            with that mammographic modal-
 MD 20824-9998.                            xeromammography are mentioned            ity before they can lawfully begin
                                           as examples; what about MRI and          to use it independently.
                                           ultrasound?




10       Mammography Matters, Summer 1998
 Q & A (continued)
                                                                                   request by fax to 301-986-8015 or
   Q       I am giving a talk on the      A         Yes. FDA has produced          by mail to MQSA, c/o SciComm,
         final regulations at an                 an MQSA Final Regulations          Inc., P.O. Box 30224, Bethesda,
     upcoming meeting. Does FDA              Speaker’s Kit consisting of a         MD 20824-9998. Be sure to
   have any materials that would help     speech, slides, overheads, and           include your name, organization,
   me prepare my speech?                  additional background informa-           full address, phone and fax num-
                                          tion in slide and overhead formats.      bers. A copy of the speech is also
                                          Speakers may borrow these kits           available on FDA’s website at
                                          (pending availability) for a 30-day      http://www.fda.gov/cdrh/dmqrp.
                                          period at no charge. Submit your         html.


Mobile Units
Continued from page 9

At the very least, says Divine, the           DA has recently accepted successful completion of three more mammog-
entity providing the technologist and         raphy-specific courses as meeting the technologist initial training require-
the mammography unit must be certi-           ments, even though they are less than 40 hours in length. The courses are:
fied. These situations present a unique
challenge to inspectors, who must         Achieving Quality Images: 3-Day Mammography Seminar, provided by
inspect the entire process. With joint    Achieving Quality Images of East Grand Rapids, Michigan at 1-800-522-
certification, the inspection must be      3439.
coordinated, and the two facilities and   Mammography, provided by Rose State College of Midwest City, Okla-
their staff and equipment must be         homa. Contact Jo Bishop at 405-733-7569.
available at the same time.
                                          Initial Mammography Training, provided by Mammography Accreditation
                                          Consultants, Rock Hall, MD. Contact Judith Hagerty or Gerry Lockwood
                                          at 1-800-570-2511.
Operators of mobile units can turn
to a variety of resources for more        For more information on meeting this requirement, as well as other course
information and assistance. Facilities    listings, see Mammography Matters, Spring 1996, Fall 1996, and Spring 1997.
and operators may want to access
information on the Internet
(www.fda.gov/cdrh/dmqrp.html) or
call the facility telephone hotline (1-
800-838-7715) for clarification of or
guidance regarding the final regula-       Facilities must notify their ACCREDITATION BODY of any changes in
tions.                                    their mailing address information, such as new contact person, change of
                                          address, or change of facility name.
                                               FDA relies on the address information provided by the accreditation
                                          bodies and cannot change or modify a facility’s address.
                                               Failure to notify your ACCREDITATION BODY of any address
                                          changes may result in you’re not receiving important MQSA mailings such
                                          as Federal Register notices or Mammography Matters.


                                                                         Mammography Matters, Summer 1998               11
 Name and Address Changes:                                   Accreditation, Certification,
 If your mailing label code includes either:                 and Commercial Products
 ACR, SAR, SCA, or SIA, notify your accreditation
 body of any name and/or address changes.                    FDA neither endorses nor requires the use of any spe-
                                                             cific x-ray system component, measuring device, soft-
 Otherwise submit your address changes to:                   ware package, or other commercial product as a condi-
 MQSA, c/o SciComm Inc., P Box 30224,
                            .O.                              tion for accreditation or certification under MQSA.
 Bethesda, MD 20824-9998. Fax 301-986-8015.                       Any representations, either orally or in sales litera-
                                                             ture, or in any other form, that purchase of a particular
                                                             product is required in order to be accredited or certi-
                                                             fied under MQSA should be reported to FDA imme-
                                                             diately so that appropriate action may be taken.




 Mammography Matters is a publication of the Food and Drug Administration, Center for Devices and Radiological Health



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