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OSHA 1915.1001AppE

Chest X-ray classification

Subpart Z

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1001 App E, must chest X-rays be classified using a specific international system?

Yes. Chest X-rays must be classified in accordance with the ILO International Classification of Radiographs of Pneumoconioses (revised edition 2011), as required by 1915.1001 App E. The rule also requires recording the classification on a CDC/NIOSH (M) 2.8 form with at least the content in items 1 through 4.

Under 1915.1001 App E, who is qualified to classify chest X-rays for pneumoconioses?

Only a qualified reader may classify chest X-rays: a B-Reader, a board eligible/certified radiologist, or an experienced physician with known expertise in pneumoconioses, per 1915.1001 App E. Employers must ensure the person doing the classification meets one of those categories.

Under 1915.1001 App E, what form must be used to record chest X-ray classifications?

Classifications must be recorded on a CDC/NIOSH (M) 2.8 form, and at minimum the information within the bold lines (items 1 through 4) of that form must be included, as required by 1915.1001 App E. The regulation states this specific format but clarifies the form itself is not to be submitted to NIOSH.

Under 1915.1001 App E, can an untrained clinician classify chest X-rays if supervised by an experienced physician?

No. Chest X-rays must be classified only by a B-Reader, a board eligible/certified radiologist, or an experienced physician with known expertise in pneumoconioses, so an untrained clinician cannot perform official classifications even under supervision, according to 1915.1001 App E. Employers must ensure the classifier meets one of the specified qualifications.

Under 1915.1001 App E, what reference materials must the physician have when classifying film chest X-rays?

When classifying film chest X-rays, the physician must have immediately available a complete set of the ILO standard format radiographs provided for use with the ILO Guidelines (revised 2011), per 1915.1001 App E. This ensures consistent comparison to the ILO standards during classification.

Under 1915.1001 App E, what must a physician have when classifying digitally-acquired chest X-rays?

For digitally-acquired chest X-rays, the physician must have immediately available a complete set of ILO standard digital chest radiographic images for reference, and the classification must be based on viewing electronic copies—not on printed transparencies—per 1915.1001 App E.

Under 1915.1001 App E, are hard-copy prints acceptable for classifying digital chest X-rays?

No. Classification of digitally-acquired chest X-rays must be based on viewing images displayed as electronic copies and shall not be based on viewing hard copy printed transparencies, according to 1915.1001 App E. This maintains fidelity to digital image characteristics.

Under 1915.1001 App E, is the CDC/NIOSH (M) 2.8 form required to be submitted to NIOSH?

No. The regulation requires using the CDC/NIOSH (M) 2.8 form format for recording classifications, but explicitly states that this form is not to be submitted to NIOSH, per 1915.1001 App E.

Under 1915.1001 App E, what minimum items must be included when recording chest X-ray classifications?

At minimum, the content within the bold lines of the CDC/NIOSH (M) 2.8 form (items 1 through 4) must be included when recording classification results, as required by 1915.1001 App E. Employers should ensure those fields are completed for each classified film.

Under 1915.1001 App E, can a non-physician technician be listed as the classifier on the CDC/NIOSH (M) 2.8 form?

No. Because the standard requires classification only by a B-Reader, a board eligible/certified radiologist, or an experienced physician with known expertise in pneumoconioses, the classifier listed on the CDC/NIOSH (M) 2.8 form must be one of those qualified individuals, per 1915.1001 App E.

Under 1915.1001 App E, if an employer uses a board-certified radiologist who is not a B-Reader, is that acceptable?

Yes. The regulation allows classification by a board eligible/certified radiologist even if they are not a B-Reader, as long as they have recognized expertise in diagnosing pneumoconioses, per 1915.1001 App E. Employers should document the radiologist's qualifications.

Under 1915.1001 App E, must the physician use a particular edition of the ILO Guidelines?

Yes. The regulation specifies use of the Guidelines for the use of the ILO International Classification of Radiographs of Pneumoconioses (revised edition 2011), and the physician must have the ILO standard radiographs available for reference when classifying, as stated in 1915.1001 App E.

Under 1915.1001 App E, can a physician use an incomplete or unofficial ILO reference set when classifying X-rays?

No. The physician must have immediately available a complete set of the ILO standard format radiographs (for film) or a complete set of ILO standard digital images (for digital), as required by 1915.1001 App E. Using incomplete or unofficial reference sets would not meet the rule's requirement.

Under 1915.1001 App E, does the requirement to use electronic copies for digital X-rays mean employers must provide specific viewing hardware or software?

The rule requires classification of digitally-acquired chest X-rays based on viewing images displayed as electronic copies and having ILO standard digital images immediately available for reference, but it does not prescribe specific hardware or software; employers must ensure the viewing system preserves diagnostic image quality and allows comparison to the ILO digital standards, per 1915.1001 App E.

Under 1915.1001 App E, how should employers document that an X-ray was classified according to the ILO system?

Employers should document the classification on the CDC/NIOSH (M) 2.8 form including at least items 1–4 and identify that the ILO (2011 revised) classification system was used and who performed the reading (B-Reader, board eligible/certified radiologist, or experienced physician), as required by 1915.1001 App E. Keep completed forms in the employee medical record as appropriate.

Under 1915.1001 App E, are employers required to send classified X-ray forms to NIOSH?

No. The regulation explicitly states the CDC/NIOSH (M) 2.8 classification form is not to be submitted to NIOSH; it is to be used for recording classifications locally, per 1915.1001 App E.

Under 1915.1001 App E, what should an employer do if the only available classifier is experienced but not board-certified or a B-Reader?

If the physician has known expertise in pneumoconioses, that physician may classify chest X-rays even if not board-certified or a B-Reader, because 1915.1001 App E allows an 'experienced physician with known expertise in pneumoconioses' to perform classifications; employers should document the physician's relevant experience and credentials.

Under 1915.1001 App E, does the requirement to use the ILO 2011 guidelines apply to both film and digital radiographs?

Yes. The ILO International Classification (revised 2011) must be used for classifying both film and digitally-acquired chest radiographs, with film readers using the ILO standard format radiographs and digital readers using the ILO standard digital chest radiographic images, as stated in 1915.1001 App E.