Michigan: radiation safety rules for fluoroscopy teams

No. Michigan is not an NRC Agreement State, so the NRC regulates radioactive materials there directly.

Michigan Administrative Code R 333.5001-R 333.5721, "Ionizing Radiation Rules Governing the Use of Radiation Machines." Most rules took effect 5/25/2016. R 333.5065 was amended in 2023 and Part 5 was added effective 3/13/2024. Part 3 contains the general protection standards, Part 7 covers medical X-ray (fluoroscopy at R 333.5337,.5347 and.5348) and Part 5 covers operator qualifications. The governing statute is MCL 333.13501 et seq.

ALARA is defined in R 333.5002(5), but no operative requirement to keep doses ALARA was found. The closest provisions are R 333.5093(1)(a) (instruction in precautions to minimize exposure) and R 333.5348(2) (only necessary people in the fluoroscopy room).

Where ALARA lives in Michigan: No ALARA requirement found for X-ray users. The ALARA definition appears only in the radiation-machine rules (R 333), which since 2016 apply only to machines, and no rule imposes it. The NRC regulates radioactive materials in Michigan directly. The status of the older R 325.5001 et seq. rules is unconfirmed. (R 333.5002(5); LEO notice "New Radiation Machine Rules Now Effective" (5/25/2016))

0.05 Sv (5 rem), or 50 mSv per year, effective dose equivalent. Minors are limited to 10% of adult limits.

0.15 Sv (15 rem), or 150 mSv per year. No lower limit has been adopted.

0.5 Sv (50 rem), or 500 mSv per year, shallow dose equivalent to the skin of the whole body or the extremities.

5 mSv (500 mrem) to the embryo/fetus of a declared pregnant woman over the entire pregnancy.

The general rule requires a dosimeter for adults likely to exceed 10% of a limit, minors above set lower levels, declared pregnant women likely to exceed 1 mSv, and anyone entering a high radiation area. For diagnostic X-ray, every occupationally exposed person must be monitored. Under policy MIOSHA-RSS-118, only the operator of a mini C-arm needs a dosimeter.

With an apron, the whole-body badge goes at the unshielded location of highest exposure, typically the neck. The lens badge goes at the neck or nearer the eye, and the fetal badge at the waist under the apron. With one collar badge, the deep dose counts as the effective dose, or the deep dose may be multiplied by 0.3 if it exceeds 25% of the limit. With two badges, effective dose is 1.5 × waist + 0.04 × neck. The department may approve other methods. R 333.5348(5) conflicts by saying badges are normally worn on the chest or abdomen.

Everyone in a fluoroscopy room except the patient must wear an apron of at least 0.5 mm lead equivalence. Fixed fluoroscopes need drapes or panels of at least 0.25 mm lead equivalence. Mobile-unit operators need a 0.5 mm apron unless 1.6 mm portable shielding is provided. No thyroid shield or eyewear requirement was found.

not found

The rules do not address engineered shielding systems, and R 333.5348(1) requires aprons for everyone present. R 333.5015 allows exemptions where there is no undue hazard. Secondary sources report that Michigan certified one engineered shielding system for use without aprons, but no primary state record was found. Separately, the statute exempts operators of handheld dental X-ray systems from aprons under certain conditions (MCL 333.13527).

Facilities may not employ non-exempt people to perform medical radiologic technology unless they meet Part 5 or have the department's written approval. Article 15 licensed practitioners acting within their scope of practice, including physicians, are exempt. Whether PAs, NPs and RNs are covered is unclear. Technologists work under general supervision and students need direct supervision. Violations are cited against the facility.

There is no state license or fluoroscopy permit, and none is planned. Operators need a recognized credential, such as American Registry of Radiologic Technologists (ARRT) (R) or CAMRT, or for cardiac and interventional work ARRT CV, CI or VI or CCI RCIS. Temporary status lasts up to 3 years after an approved program. Conditional status based on a signed statement of assurance ends March 13, 2027. Limited radiographers need 40 hours of training plus 12 continuing education (CE) credits every 24 months, and their categories exclude fluoroscopy. No fluoroscopy-specific training requirement for physicians was found.