Is Maryland an NRC Agreement State?
Yes. Maryland is not on the NRC list of non-Agreement States, and the NRC reviewed Supplement 35 for compatibility on 8 August 2025.
What Maryland's rules say about ALARA (as low as reasonably achievable), dose limits in millisieverts (mSv), dosimeters, aprons and training for the people who work in fluoroscopy labs.
Please double-check this information. This is an ORSIF research summary, researched November 3, 2026, with its weakest answers rechecked November 5, 2026. It is not comprehensive and not always accurate: rules change, and answers may be incomplete, out of date or wrong. It is education, not legal advice. Not yet reviewed by a regulatory expert. Confirm each requirement at the source linked beside the answer, with the state program and with your facility's radiation safety officer. How this was made
ORSIF's research identified the Radiological Health Program (RHP), Air and Radiation Administration, Maryland Department of the Environment (MDE) as the agency that regulates X-ray and fluoroscopy equipment in Maryland. Maryland is a U.S. Nuclear Regulatory Commission (NRC) Agreement State: it has signed an agreement with the NRC to regulate certain radioactive materials itself.
Maryland's X-ray rules share a document with its radioactive-materials rules (Regulations for the Control of Ionizing Radiation (1994), adopted by COMAR 26.12.01.01); ALARA is in shared Part D, so an NRC change could affect X-ray users, while Part F has its own duty to minimize exposure. Dose limits follow the NRC model: 50 mSv whole body, 150 mSv lens, 500 mSv skin/extremity and 5 mSv embryo/fetus, and a D.209 formula estimates fluoroscopy effective dose from one or two badges. Supplement 35 (effective 15 September 2025) deleted the general 0.25 mm apron rule, leaving a fluoroscopy standard of 0.25 mm lead-equivalent shielding or 120 cm distance; aprons need no scheduled inspection, and alternatives to aprons are not addressed by name. Only licensed practitioners or radiological technologists may energize fluoroscopy, with 4 hours of initial training and 1 hour every 2 years.
Every answer names the rule it comes from. Open "Rule text and source" to read the citation, the source page and, where it could be matched, the exact wording.
Which rules apply, and whether ALARA is among them.
Yes. Maryland is not on the NRC list of non-Agreement States, and the NRC reviewed Supplement 35 for compatibility on 8 August 2025.
COMAR 26.12.01.01 adopts by reference the "Regulations for the Control of Ionizing Radiation (1994)," as amended through Supplement 35 (effective 15 September 2025). The relevant parts are Part D (Standards for Protection Against Radiation, applying to licensees and registrants) and Part F (X Rays in the Healing Arts: F.3 general, F.5 fluoroscopy). COMAR 26.12.02 covers machine inspection and certification. There is no free official online text, so the research relied on unofficial MDE copies.
COMAR 26.12.01.01 includes the "Regulations for the Control of Ionizing Radiation (1994)", which is incorporated by reference.This quote was matched word for word to a page the research read.
Yes. D.101(a) requires each licensee or registrant to keep occupational doses ALARA, and Part D's scope (D.2) covers registrants. D.101(e) lets registrants build the D.209 fluoroscopy method into their ALARA program.
Where ALARA lives in Maryland: In a shared rule and in X-ray-specific language. The ALARA requirement (D.101(a)) is in shared Part D, which covers both licensees and registrants. D.101(e) and D.209 refer to an "ALARA program." Part F has a separate X-ray-specific duty to minimize exposure (F.3(a)(1)(x)) without using the term ALARA, and this duty would survive an NRC-driven change to Part D. (§D.101(a)-(b), (e); §F.3(a)(1)(x)-(xi) (Supp. 35 numbering))
a licensee or registrant shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to the members of the general public that are as low as is reasonably achievable (ALARA).This quote was matched word for word to a page the research read.
The annual limits for workers, written in millisieverts (mSv). Ten mSv equal one rem.
Total effective dose equivalent of 0.05 Sv (5 rem), which is 50 mSv per year.
The total effective dose equivalent being equal to 0.05 Sv (5 rem); or (2) The sum of the deep dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 0.5 Sv (50 rem).This quote was matched word for word to a page the research read.
0.15 Sv (15 rem), which is 150 mSv per year. No lower International Commission on Radiological Protection (ICRP)-style limit has been adopted.
(1) A lens dose equivalent of 0.15 Sv (15 rem), and (2) A shallow-dose equivalent of 0.5 Sv (50 rem) to the skin of the whole body or to the skin of any extremity.This quote was matched word for word to a page the research read.
0.5 Sv (50 rem), which is 500 mSv shallow-dose equivalent to the skin of the whole body or any extremity.
(1) A lens dose equivalent of 0.15 Sv (15 rem), and (2) A shallow-dose equivalent of 0.5 Sv (50 rem) to the skin of the whole body or to the skin of any extremity.This quote was matched word for word to a page the research read.
5 mSv (0.5 rem) to the embryo/fetus of a declared pregnant woman over the whole pregnancy. A footnote cites the National Council on Radiation Protection and Measurements (NCRP) Report 91 recommendation of no more than 0.5 mSv in any one month.
The licensee or registrant shall ensure that the dose equivalent to an embryo/fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, does not exceed 5 mSv (0.5 rem).This quote was matched word for word to a page the research read.
When a worker must wear a dosimeter, and where.
Badges are required for adults likely to exceed 10% of a D.201 limit in a year (5 mSv whole body, 15 mSv lens, 50 mSv skin or extremity), minors above 1 mSv deep dose, declared pregnant women likely to exceed 1 mSv, and anyone entering a high or very high radiation area.
Adults who potentially may receive, in 1 year, from sources external to the body, a dose in excess of 10 percent of the limits in D.201a;This quote was matched word for word to a page the research read.
When an apron is worn, at least one badge must be worn at the collar outside the apron. Under D.209, for C-arm interventional fluoroscopy, effective dose can be estimated as the collar reading, as collar × 0.3 once the collar reading exceeds 25% of the limit, or as 1.5 × waist (under apron) + 0.04 × collar with two badges. The registrant must notify MDE when a worker reaches 80% (40 mSv).
the sum of the deep dose equivalent reported for the individual monitoring device located at the waist under the protective apron multiplied by 1.5 and the deep dose equivalent reported for the individual monitoring device located at the neck outside the protective apron multiplied by 0.04.This quote was matched word for word to a page the research read.
Protective apparel, how it is checked, and whether other systems are addressed.
Supplement 35 deleted the general rule requiring aprons or whole-body barriers of at least 0.25 mm lead equivalent. For fluoroscopy, F.5(i) still requires 0.25 mm lead-equivalent shielding against under-table scatter. For above-table scatter, staff must be at least 120 cm from the beam centre or behind at least 0.25 mm lead-equivalent material. Thyroid shields and eyewear for staff are not addressed.
remove Sections F.3(a)(1)(viii), F.3(a)(1)(ix), and F.3(a)(1)(x), on page F11;This quote was matched word for word to a page the research read.
Maryland's X-ray rules do not require protective aprons or gloves to be inspected on a schedule. They define protective aprons and gloves and say where a dose badge goes when an apron is worn, but they set no inspection duty.
"Protective apron" means an apron made of radiation absorbing materials used to reduce radiation exposure.This quote was matched word for word to a page the research read.
Not addressed by name. Instead of naming aprons, Maryland's fluoroscopy rule sets a shielding standard: no part of a staff member's body except the extremities may be exposed to unattenuated scattered radiation from above the tabletop unless the person is at least 120 centimeters from the center of the beam, or the radiation has passed through at least 0.25 mm lead-equivalent material "including, but not limited to" drapes, bucky-slot cover panels or self-supporting curtains.
Is at least 120 centimeters from the center of the useful beam, or (ii) Is in a location such that the radiation has passed through not less than 0.25 millimeter lead equivalent material including, but not limited to, drapes, bucky-slot cover panel, or self-supporting curtains.This quote was matched word for word to a page the research read.
Who may use fluoroscopy equipment and what training the rules ask for.
Only a licensed practitioner of the healing arts or a radiological technologist may energize fluoroscopy equipment; "radiological technologist" is undefined. Under Board of Physicians rules, radiographers and radiologist assistants may perform fluoroscopy under supervision. RCIS may assist but may not perform fluoroscopy. PAs are limited to nonfluoroscopic mini C-arm work from 1 October 2026. Limited X-ray operators are barred, and no provision for NPs was found.
The registrant shall ensure that only a licensed practitioner of the healing arts or a radiological technologist be allowed to energize fluoroscopic x-ray systems.This quote was matched word for word to a page the research read.
At least 4 hours of training before clinical use, plus at least 1 hour of in-service or continuing medical education (CME) every 24 months. Records are kept for 3 years. Certified radiologists and therapy-simulation-only users are exempt. There is no separate state fluoroscopy permit. RCIS need 40 hours of didactic training plus supervised clinical training.
all persons energizing these systems shall have completed at least four hours of training as specified in Section F.5(n)(2) prior to clinical use of a fluoroscopic systemThis quote was matched word for word to a page the research read.
Rules, bills and guidance the research found from 2025 and 2026, with the ones that touch fluoroscopy teams first.
Adopted; effective; NRC found compatible 8 August 2025 (Sep 15, 2025)
Deleted the general apron/barrier rule and patient gonad and thyroid shielding (F.3(a)(1)(viii)-(x)). Removed the apron reference in F.5(i)(2)(ii). Annual dose reports to workers are now required only above 1 mSv (J.13(b)).
Approved 28 April 2026; effective 1 October 2026 (Oct 1, 2026)
Creates Board of Physicians registration for limited X-ray machine operators, who are excluded from fluoroscopy. Moves the RCIS fluoroscopy-assist rule to a new §14-306.1. Limits PAs to nonfluoroscopic mini C-arm work on the extremities.
Listed in MDE regulations in development
Fee update for the Radiological Health Program; it is the only item on the list, and nothing is pending for COMAR 26.12.01.
Questions the research could not settle. If you know the answer, tell us.
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