Massachusetts: radiation safety rules for fluoroscopy teams

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

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.

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))

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

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.

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

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.

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 The 1998 DRC guidance notice (AIN 98-01) describes only the 10% test and is out of date for fluoroscopy.

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)).

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.

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.

The rules do not expressly address engineered radiation protection systems. However, staff may be protected from scatter radiation by either protective aprons or whole body protective barriers of at least 0.25 mm lead equivalent, so a barrier-type alternative to the apron is accepted.

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)).

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.