Scenario: a general clinic wants to invest in X-ray and MRI machines. The owner asks: beyond the medical operation licence, are extra radiation permits needed, and who may operate the machines?
Diagnostic imaging: techniques within approved lists
Diagnostic imaging (X-ray, CT, MRI, ultrasound) comprises medical techniques — establishments may perform them only where listed in approved technique catalogues of operation licences (Law on Medical Examination and Treatment 15/2023/QH15, Decree 96/2023/ND-CP). Performers (imaging doctors, technicians) must hold practising licences with matching scope. General clinics adding X-ray or MRI must complete technique-list supplementation — never buy machines and scan before approval.
Radiation safety: separate permits beyond medical licences
The key specialty: X-ray and CT equipment uses ionising radiation — beyond medical operation licences, establishments must follow atomic-energy and radiation-safety law: hold radiation-work licences (for medical X-ray equipment use); train operators in radiation safety; maintain shielded, inspected imaging rooms; keep patient doses optimised (as low as reasonably achievable while ensuring diagnosis); monitor staff occupational doses. MRI uses no ionising radiation, so it escapes X-ray/CT-style radiation regulation — but remains a technique requiring approved listing, trained operators and its own safety contraindications (metallic implants, pacemakers). Radiation-safety breaches draw administrative fines in the atomic-energy sector — independent of medical administrative fines.
Liability for wrong imaging diagnoses
Imaging doctors answer for film-reading results within professional scope — misreading or missing lesions is professional error where breaching professional procedures. Ordering clinicians share responsibility: unnecessary orders (CT or X-ray overuse) cost patients money and needless radiation exposure — breaching designation rules. With AI-assisted film reading spreading, doctors remain final signatories bearing responsibility — AI is only assistive. Patients may refuse unnecessary imaging, demand order justifications, and complain against abusive ordering.
Frequently asked questions
X-rays for pregnant women — risks?
Ionising radiation threatens foetuses — the principle is maximum limitation, imaging only where truly necessary with shielding. Establishments must ask about and screen women of childbearing age before X-ray or CT scans. Breaching foetal-protection procedures violates radiation safety.
May private clinics invest in MRI?
Yes, where meeting conditions: supplemented technique lists, imaging doctors, trained technicians, facilities (machine rooms, magnetic shielding). MRI is a major investment — calculate efficiency and complete compliance before buying.
Conflicting film readings from two places?
Imaging diagnosis involves professional judgment — inter-doctor differences occur. Patients may seek second opinions. In disputes, Professional Councils and independent medical assessment evaluate.
This article has been quality-reviewed by the FLAW AI Legal Council.
