​​Purpose of this Notice

This notice informs facilities of the recent amendment to California Health and Safety Code §106985, governing when and how Certified Radiologic Technologists (CRTs) may perform venipuncture for the administration of contrast materials to an upper extremity. The amendments clarify supervision requirements and facility responsibilities.  Facilities must update internal procedures to ensure compliance with the amended statute.

Summary of Key Amendments

Direct Supervision – Expanded Definition

A supervising licensed physician and surgeon may now provide direct supervision in two ways:

1. Physically present within the facility and immediately available to intervene (“onsite"), or
2. Immediately available via real‑time audio and video communication, with access to the patient's electronic medical imaging record, and able to intervene by directing other onsite personnel (“remote").

This expands prior law, which required the physician to be physically present in the same facility.

Personnel Required for Responding to Adverse Events

The amended law requires:

• Safety protocols and onsite personnel capable of responding to adverse events at the supervising physician's direction.
• The onsite personnel shall be licensed or certified as a physician and surgeon, registered nurse, nurse practitioner, clinical nurse specialist, or physician assistant.
• This requirement applies to only to facilities where the supervising physician and surgeon is providing direct supervision remotely.

Facility Responsibilities

To comply with the amended law, facilities must:

• Review and update written protocols, ensuring they meet amended HSC §106985 requirements.
• Document physician supervision arrangements, including whether supervision is onsite or remote.
• Identify and maintain qualified onsite personnel capable of responding to adverse events.
• Maintain documentation of each CRT's didactic training, supervised venipunctures, and competency verification.
• Prepare records for inspection by the Radiologic Health Branch (RHB), including training records, supervision protocols, and personnel licensure.

​Questions or Assistance

Facilities with questions regarding implementation or compliance may contact the Radiologic Health Branch at: rhbxrayinspectionchief@cdph.ca.gov