Larger chest X-ray film under OSHA standards

February 16, 1993
David Lee Sirott
Regional Client Representative
PHS Multi-Phase Testing
[Recipient address omitted]
Dear Mr. Sirott:
Thank you for your letter of December 3, 1992 addressed to the Occupational Safety and Health Administration (OSHA) regarding the acceptability of x-rays done on 16" x 17" film in lieu of the 14" x 17" size as specified in several OSHA regulations. Please accept our apology for the delay in this response.
You requested to know whether or not OSHA's position statement as indicated in the May 12, 1983 letter to you, is still in effect, since you had been informed by one of your clients that they had a letter to the contrary.
OSHA's position as stated in the May 12, 1983 letter to you, remains the same. The use of 16" x 17" chest x-rays in lieu of the 14" x 17" size is generally acceptable for purposes of meeting OSHA's standards. Bear in mind that the May 12, 1983 letter also stipulated that there may be specific requirements under 42 CFR 1937.41 for the chest x-rays of underground coal miners that prohibit the use of any other size film besides the 14" x 17" size.
Thank you for the opportunity to clarify this issue for you.
Sincerely,
Ruth McCully, Director
[Office of Health Enforcement]
[Corrected 10/22/2004]

[Requester letter reproduced on OSHA page; omitted here.]

May 12, 1983
Mr. Michael Kleinman
Vice President,
Marketing and Sales
Professional Health Services, Inc.
[Recipient address omitted]
Dear Mr. Kleinman:
This is in response to your letter of February 2, 1983, requesting an interpretation on the acceptability of X-rays done on 16" x 17" film in lieu of the 14" x 17" size as specified in several OSHA regulations. Please accept my apology for the delay in response.
According to the information that you supplied, the expanded format of the 16" x 17" X-rays appears to be identical in magnification and quality to the regular 14" x 17" size. In this regard, we contacted Dr. Edgar L. Dessen, Chairman of the Task Force on Pneumoconioses of the American College of Radiology. He encourages permitting the larger sized chest X-ray films, since workers with a large frame must at times receive multiple X-ray exposures using the standard sized films, whereas the larger films could accommodate them with a single exposure.
In addition, Ms. Mitzie Martin, Chief of Receiving Center Section of the Examination Processing Branch of NIOSH in Morgantown, was called concerning the question of the storage of the larger X-ray film. She indicated that these X-ray films could be accepted for storage under 29 CFR 1910.1020(h)(3), and that the larger size could be accommodated due to the small volume that would be received, if any were sent at all.
The use of 16" x 17" chest X-rays, therefore, appears to be in compliance with all current OSHA regulations that require 14" x 17" film and therefore are acceptable for this purpose.
For your information, NIOSH's Examination Processing Branch does receive a large volume of chest X-ray films of underground coal miners under provisions of the program covering these workers at 42 CFR 37.41. It is our understanding that these regulations call for X-rays to be taken on 14" X 17" film, with no other size acceptable that could meet the specifications for monitoring in the NIOSH program. You may wish to contact Ms. Martin if you have any further questions; her phone number is (304) 291-4301.
We trust that this clarification is useful. If you have any further questions, please do not hesitate to contact us again.
Sincerely,
Bruce Hillenbrand, Acting Director,
[Directorate of Cooperative and State Programs]