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Please double-check this information. This is an ORSIF research summary, researched November 3, 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 It is not comprehensive and not always accurate: rules change, and answers may be incomplete, out of date or wrong.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

In brief

ORSIF's research identified the Division of Radiation Control (DRC), Radiation Control Program, Bureau of Climate and Environmental Health, Massachusetts Department of Public Health (DPH) as the agency that regulates X-ray and fluoroscopy equipment in Massachusetts. Massachusetts is a U.S. Nuclear Regulatory Commission (NRC) Agreement State: it has signed an agreement with the NRC to regulate certain radioactive materials itself.

Massachusetts requires X-ray registrants, including fluoroscopy users, to keep worker doses ALARA under 105 CMR 120.210(B). This rule sits in Part 120.200, which is shared with radioactive-materials licensees. The X-ray part (120.403) separately calls for minimizing personnel exposure. Dose limits match the federal numbers: 50 mSv whole body, 150 mSv lens (no lower limit adopted), 500 mSv skin/extremities, and 5 mSv embryo/fetus. All fluoroscopy workers must wear dosimeters, and the rules specify badge placement and one- or two-badge effective-dose calculations. Staff need aprons or whole-body protective barriers of at least 0.25 mm lead equivalent, plus lead glasses for interventional procedures. Protective equipment must be X-rayed annually. Engineered radiation protection systems are not expressly addressed. Only radiologists, trained physicians, licensed radiologic technologists trained in fluoroscopy, and qualifying physician assistants may operate fluoroscopy.

The rules, question by question

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.

Where the rules live

Which rules apply, and whether ALARA is among them.

Is Massachusetts an NRC Agreement State?

Yes

Yes. Massachusetts is on the NRC's list of Agreement States, updated October 29, 2026.

Rule text and source
Rule
NRC list of Agreement States, updated October 29, 2026; NRC letter to MA DPH, May 22, 2025 (Tracking Ticket 25-29).
Source
nrc.gov
What it says
These regulations were reviewed by comparison to the equivalent U.S. Nuclear Regulatory Commission (NRC) rules
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Which rules cover X-ray and fluoroscopy equipment in Massachusetts?

Yes

105 CMR 120.000 (Massachusetts Regulations for the Control of Radiation) is one combined rule. The relevant parts are 120.400 X-rays in the Healing Arts (120.403 general requirements; 120.405 fluoroscopic systems) and 120.200 Standards for Protection Against Radiation, which applies to both licensees and registrants. Radiologic technologist licensing is in 105 CMR 125.000. The posted 105 CMR 120 PDF is Mass. Register #1480, dated 10/14/22; the 105 CMR 125 PDF is Mass. Register #1567, dated 02/13/2026. Mass.gov says the official version is the purchased print edition.

Rule text and source
Rule
105 CMR 120.202; 120.401
Source
mass.gov
What it says
Except as otherwise specifically provided in other Parts of 105 CMR 120.000, 105 CMR 120.200 applies to persons licensed or registered by the Department to receive, possess, use, transfer, or dispose of sources of radiation.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Does Massachusetts require X-ray users to keep doses as low as reasonably achievable (ALARA)?

Yes

Yes. Every licensee or registrant must use procedures and engineering controls to keep occupational doses ALARA. A radiation protection program is required (120.210(A)) and must be reviewed at least every 12 months (120.210(C)).

Where ALARA lives in Massachusetts: In a shared rule and in X-ray-specific language. The ALARA requirement is in 120.210(B), in Part 120.200, which applies to radioactive-materials licensees and X-ray registrants alike, so an NRC Part 20 compatibility change could affect it. Section 120.403(A)(1)(i) separately requires procedures and equipment that minimize personnel exposure, without using the word 'ALARA'. Section 120.403(A)(1)(j) cross-references the dose-limit sections but does not list 120.210. (105 CMR 120.210(B); 120.403(A)(1)(i); 120.403(A)(1)(j))

Rule text and source
Rule
105 CMR 120.210(B)
Source
mass.gov
What it says
The 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 members of the public that are as low as is reasonably achievable (ALARA).
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Dose limits

The annual limits for workers, written in millisieverts (mSv). Ten mSv equal one rem.

What is the annual whole-body dose limit in Massachusetts?

Yes

0.05 Sv (5 rem) = 50 mSv TEDE per year; applies to registrants as well as licensees.

Rule text and source
Rule
105 CMR 120.211(A)
Source
mass.gov

Why this matters, in ORSIF's FAQs

What is the annual eye-lens dose limit in Massachusetts?

Yes

0.15 Sv (15 rem) = 150 mSv per year. Massachusetts has not adopted a lower limit such as the International Commission on Radiological Protection (ICRP)'s 20 mSv.

Rule text and source
Rule
105 CMR 120.211(A)
Source
mass.gov
What it says
(a) a lens dose equivalent of 0.15 sievert (15 rems); and (b) a shallow dose equivalent of 0.5 sievert (50 rems) to the skin of the whole body or to the skin of any extremity.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

What is the annual limit for the skin, hands and feet in Massachusetts?

Yes

0.5 Sv (50 rem) = 500 mSv shallow dose per year to the skin and extremities.

Rule text and source
Rule
105 CMR 120.211(A)
Source
mass.gov
What it says
(a) a lens dose equivalent of 0.15 sievert (15 rems); and (b) a shallow dose equivalent of 0.5 sievert (50 rems) to the skin of the whole body or to the skin of any extremity.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

What limit applies to a declared pregnant worker in Massachusetts?

Yes

5 mSv (0.5 rem) to the embryo/fetus of a declared pregnant woman over the whole pregnancy. Employers must also avoid large variations above a uniform monthly exposure rate.

Rule text and source
Rule
105 CMR 120.218(A)
Source
mass.gov

Why this matters, in ORSIF's FAQs

Dosimeters

When a worker must wear a dosimeter, and where.

When must a worker in Massachusetts wear a dosimeter?

YesCheck the source

Adults likely to receive more than 10% of a 120.211(A) limit in a year from external sources must be badged. For declared pregnant women, the trigger is a likely deep dose above 1 mSv (0.1 rem) over the pregnancy. All individuals working medical fluoroscopic equipment must be badged, with no 10% test. The 1998 DRC guidance notice (AIN 98-01) describes only the 10% test and is out of date for fluoroscopy.

Rule text and source
Rule
105 CMR 120.226(A)(1), (3) and (5)
Source
mass.gov

Why this matters, in ORSIF's FAQs

Where must the dosimeter be worn in Massachusetts when a protective apron is worn?

Yes

Badge locations: one badge at the collar outside the apron; a second badge under the apron at the waist, which is required for a declared pregnant woman. Lens dose is measured at the collar outside the apron or at an unshielded spot closer to the eye. Extremity badges go on the extremity likely to get the highest dose. Effective dose (120.211(C)(2)): (a) with one collar badge, the deep dose counts as the effective dose; (b) with one collar badge reading above 25% of the limit, effective dose = 0.3 × deep dose; (c) with two badges, effective dose = 1.5 × waist + 0.04 × neck. The rule does not name National Council on Radiation Protection and Measurements (NCRP) Report 122, and the research did not verify the coefficients against it. Other Agency-approved methods are allowed (120.211(C)(1)).

Rule text and source
Rule
105 CMR 120.226(A)(5)(a)-(c); 120.226(C); 120.211(C)(2)
Source
mass.gov
What it says
When a second individual monitoring device is used, for the same purpose, it shall be located under the protective apron at the waist. The second individual monitoring device is required for a declared pregnant woman.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Aprons and alternatives

Protective apparel, how it is checked, and whether other systems are addressed.

Must staff in Massachusetts fluoroscopy rooms wear protective aprons or other apparel?

Yes

Staff must be protected from scatter by protective aprons or whole-body protective barriers of at least 0.25 mm lead equivalent. Anyone whose body could be hit by the useful beam needs 0.5 mm lead equivalent. Lead glasses are required for interventional procedures, with no lead equivalence specified. Facilities must have enough lead aprons and gloves for all unshielded personnel. Thyroid shields are not addressed.

Rule text and source
Rule
105 CMR 120.403(A)(1)(e)1-2; 120.403(A)(1)(h)6
Source
mass.gov
What it says
The x-ray operator, other staff, ancillary personnel, and other persons required for the medical procedure shall be protected from the direct scatter radiation by protective aprons or whole body protective barriers of not less than 0.25 millimeter lead equivalent. For interventional procedures, lead glasses shall be used.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Does Massachusetts require protective aprons to be inspected?

Yes

Yes. Aprons, gloves and shields must be X-rayed every year for defects, with a record kept. Defective items must be removed from service until repaired or replaced.

Rule text and source
Rule
105 CMR 120.403(A)(1)(i)3
Source
mass.gov
What it says
Protective equipment including aprons, gloves, and shields shall be x-rayed annually for defects, such as holes, cracks, and tears to assure reliability and integrity. A record of this test shall be maintained for inspection by the Radiation Control Program.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Do the rules in Massachusetts address engineered protection systems used in place of aprons?

UnclearLess certain

Engineered radiation protection systems are not expressly addressed. The staff-protection rule can be met with 'protective aprons or whole body protective barriers' of at least 0.25 mm lead equivalent. No DRC guidance was found on whether an engineered system counts as such a barrier. Separately, 120.405(H)(2)(b) requires 0.25 mm lead-equivalent drapes, Bucky-slot covers or self-supporting curtains above the table, in addition to the apron, unless the person is at least 120 cm from the beam center. Section 120.405(H)(1) requires 0.25 mm lead-equivalent attenuation of under-table scatter.

Rule text and source
Rule
105 CMR 120.403(A)(1)(e)2; 120.405(H)
Source
mass.gov
What it says
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, in addition to any lead equivalency provided by the protective apron
This quote was matched word for word to the source page.

About ALARA+

Who operates the equipment

Who may use fluoroscopy equipment and what training the rules ask for.

Who may operate fluoroscopy equipment in Massachusetts?

Yes

Only four groups may operate fluoroscopy: (a) licensed physicians board-certified in radiology; (b) other licensed physicians trained in seven listed subjects; (c) radiologic technologists licensed under 105 CMR 125.000 and trained in safe fluoroscopy use; (d) licensed physician assistants who meet 120.405(K)(2), with delegation by a supervising physician, a written practice agreement and a competency statement. Nurse practitioners are not listed as operators but may act as first assistants in cardiac catheterization with a qualified physician as primary operator. Students may operate only under direct supervision. Limited-scope technologists may not do fluoroscopy. Facilities must have privileging policies (120.405(K)(5)).

Rule text and source
Rule
105 CMR 120.405(K)(1), (2), (5), (9); 120.405(M)(1); 120.401; 105 CMR 125.005(B)
Source
mass.gov
What it says
The Registrant of a facility shall ensure that only the following health care providers shall be allowed to operate fluoroscopic x-ray systems:
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

What training or credentials does Massachusetts require to operate fluoroscopy equipment?

Yes

Physicians not board-certified in radiology: initial training in seven subjects (no hour count), then 2 hours of radiation safety training a year for those who perform fluoroscopy and 4 hours a year for those who supervise it. Physician assistants: didactic training in seven topics, 40 supervised clinical hours, and an American Registry of Radiologic Technologists (ARRT) or Agency-approved equivalent exam. Radiologic technologists: a state license requiring ARRT or approved board certification, plus training in safe fluoroscopy use; continuing education is 24 CEUs every two years, including 2 in radiation safety. Facilities must keep continuing education (CE) records for five years. No state fluoroscopy permit was found.

Rule text and source
Rule
105 CMR 120.405(K)(1)-(7); 105 CMR 125.005; 125.009
Source
mass.gov
What it says
The Registrant of the facility shall ensure that all physicians who are not board certified in radiology and who perform fluoroscopic procedures complete two hours of training in Radiation Safety/Radiation Protection on an annual basis
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Changes on the way, and recent ones

Rules, bills and guidance the research found from 2025 and 2026, with the ones that touch fluoroscopy teams first.

  • Adopted rule105 CMR 125.000 amendment: Limited Scope of Practice in Radiography license

    Public hearing held March 26, 2025; Public Health Council approval on December 10, 2025 reported by MSRT; posted as the Mass. Register #1567 version (Feb 13, 2026)

    Adds a limited-scope radiography license. Limited-scope licensees are excluded from fluoroscopy.

    Source: member.msrt-ma.org

  • Proposed ruleProposed 105 CMR 120 revisions (NRC SRS Tracking Ticket 25-29)

    NRC reviewed with no comments; adoption not confirmed (May 22, 2025)

    Covers radioactive-materials sections (e.g., 120.059, 120.128, 120.281, 120.282, 120.290, 120.5xx, 120.933). Does not include the occupational-dose sections (120.210-120.226) or the X-ray part (120.400).

    Source: nrc.gov

  • BillS.1637 (194th General Court)

    Sent to study order (Dec 18, 2025)

    Concerns non-ionizing radiation. No 2025-2026 bill on fluoroscopy staff protection or engineered shielding was found.

    Source: malegislature.gov

Also worth knowing

  • DRC may grant exemptions from the above-table shielding requirement (120.405(H)(2)) where a sterile field prevents normal barriers. Appendix D (120.423) lists procedures where exemptions are automatically granted, including angiograms, biopsies, myelograms and nephrostomies. No exemption is allowed where prefitted sterile covers are practical.
  • Mini C-arms are expressly covered by 120.405.
  • Facilities must keep written safety procedures reviewed annually (120.403(A)(1)(d)), and their quality assurance (QA) program must cover radiation protection for fluoroscopy (120.403(A)(6)).
  • Facilities doing interventional procedures must evaluate patient dose. Any skin dose of 2 Gy or more must go to the Radiation Safety Committee (120.405(L)).
  • Section 120.403(A)(1)(j) cites 120.215, which does not appear in the Part 120.200 table of contents (possible stale cross-reference).
  • No response by Massachusetts to the NRC's July 2026 ALARA proposal was found.

What ORSIF could not confirm

Questions the research could not settle. If you know the answer, tell us.

  • Is 105 CMR 120 current? The posted PDF is dated 10/14/22, and the 2025 radioactive-materials amendments may have since been adopted. Check the Massachusetts Register and the DPH proposed-regulations page.
  • Does DPH/DRC plan to change 120.210(B) in response to the NRC ALARA proposal, and how would it treat registrants? Check NRC's State Communication Portal and contact DRC.
  • Would DRC accept an engineered system as a 'whole body protective barrier' under 120.403(A)(1)(e)2? No guidance was found; ask DRC directly.
  • Do the 1.5/0.04 coefficients in 120.211(C)(2)(c) come from NCRP Report 122, and has DRC approved other methods under 120.211(C)(1)?
  • What is the meaning or status of the 120.215 cross-reference in 120.403(A)(1)(j)? Confirm with DRC.
  • Does 105 CMR 130.900 (hospital cardiac catheterization standards) contain additional staff radiation-safety provisions? It was not reviewed.
  • Is there any ionizing-radiation worker-protection bill in the 194th General Court? A full-text search on malegislature.gov would confirm.

Double-check before you rely on this page

ORSIF compiled this page from the sources linked on it and did its best. It is not comprehensive and it is not always accurate. Rules change, a rule may have been missed or misread, and the sources themselves can be out of date. Treat this page as a starting point.

Where to check

What may be missing here

  • 1 of 14 answers on this page are "Not found" or "Unclear". That means ORSIF did not find the answer in the rules it reviewed, not that no rule exists.
  • 2 answers carry a flag or a lower confidence ("Check the source" or "Less certain").
  • Researched November 3, 2026. Rules may have changed since.
  • Only the state's rules for X-ray and fluoroscopy equipment were reviewed.

Found something wrong or missing? Tell ORSIF.

Sources and terms

Terms used on this page
ALARA
As low as reasonably achievable: keep radiation doses as low as is reasonable, below the legal limits.
Agreement State
A state that has signed an agreement with the U.S. Nuclear Regulatory Commission to regulate certain radioactive materials itself.
mSv
Millisievert, a unit of radiation dose. Ten mSv equal one rem, the older unit some rules still use.
Dosimeter
A badge or device worn to measure a worker's radiation dose.
Lead equivalent
The thickness of lead (mm Pb) that would give the same protection as the material described.
NRC
U.S. Nuclear Regulatory Commission
ICRP
International Commission on Radiological Protection
NCRP
National Council on Radiation Protection and Measurements
TEDE
Total effective dose equivalent
ARRT
American Registry of Radiologic Technologists
CE
Continuing education
QA
Quality assurance
All 13 sources the research read

Found something out of date or wrong? Tell ORSIF. Corrections are checked against the rule text and the page is updated.