The Evidence
Resources
Clinician AssessmentGet Your Risk Score FAQs Admin ToolkitMembers Economic Impact Research ArticlesMembers SIRP 2025 WebinarMembers Videos
Guidelines
What is ALARA+? US Guidelines International Guidelines News Is Not Here About Contact Donate
Join Free

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 It is not comprehensive and not always accurate: rules change, and answers may be incomplete, out of date or wrong.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 New Mexico Environment Department (NMED), Environmental Protection Division, Radiation Control Bureau (RCB), Radiation Machine Program; rules adopted by the Environmental Improvement Board as the agency that regulates X-ray and fluoroscopy equipment in New Mexico. New Mexico is a U.S. Nuclear Regulatory Commission (NRC) Agreement State: it has signed an agreement with the NRC to regulate certain radioactive materials itself.

New Mexico's ALARA requirement is in 20.3.4 NMAC (404(B)), which covers both X-ray registrants and radioactive-materials licensees; the 1995-era X-ray rule 20.3.6 never uses the term ALARA but requires procedures that minimize personnel exposure. Dose limits match federal ones: 50 mSv whole body, 150 mSv lens, 500 mSv skin/extremity, 5 mSv embryo/fetus. 20.3.4 includes fluoroscopy apron badge-placement and effective-dose rules. Aprons or whole-body barriers of at least 0.25 mm Pb eq are required; engineered systems are not named. Licensed practitioners may operate without an imaging license, technologists need American Registry of Radiologic Technologists (ARRT)-based licensure, and limited licensees may not use fluoroscopy. A major 20.3.6 rewrite, including annual apron integrity checks, goes to EIB hearing on Nov 6, 2026.

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 New Mexico an NRC Agreement State?

Yes

Yes. New Mexico is not on the non-Agreement list, consistent with a May 1, 2026 NRC letter reviewing New Mexico's 20.3.4 revisions for compatibility.

Rule text and source
Rule
NRC list of Agreement States, updated October 29, 2026; NRC letter ML26117A340
Source
nrc.gov
What it says
We have reviewed the final revisions to the New Mexico regulations 20.3.4 NMAC, which were submitted to our office on April 14, 2026, to correct a regulatory reference error.
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 New Mexico?

Yes

20.3.6 NMAC, "X-Rays in the Healing Arts" (history notes 5-3-95, recompiled 11/27/01; about 30 years old, with a replacement pending). General standards are in 20.3.4 NMAC (effective 4/30/2009, later amended). Related rules are 20.3.1 and 20.3.2 NMAC.

Rule text and source
Rule
20.3.6 NMAC; 20.3.4.2 NMAC (scope)
Source
srca.nm.gov
What it says
Except as specifically provided in other parts of this chapter, this part 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 New Mexico require X-ray users to keep doses as low as reasonably achievable (ALARA)?

Yes

Yes. 20.3.4.404(B) requires each licensee or registrant to keep occupational doses ALARA, which covers X-ray and fluoroscopy registrants. The radiation protection program must be reviewed every 12 months and covered with all employees at hire and annually thereafter (amended 5/1/2024).

Where ALARA lives in New Mexico: Only in a rule shared with radioactive materials. The binding ALARA requirement is in 20.3.4.404(B), which covers both licensees and registrants, and the 20.3.1.6(B) objective also refers to ALARA. Current 20.3.6 never uses the term; its closest wording is the 'minimize… personnel exposure' language in 602(A)(1)(i). The pending draft would add an ALARA objective in 20.3.6.6(B). (20.3.4.404(B); 20.3.1.6(B); 20.3.6.602(A)(1)(i); proposed 20.3.6.6(B))

Rule text and source
Rule
20.3.4.404(B) NMAC
Source
srca.nm.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 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 New Mexico?

Yes

5 rem (50 mSv) total effective dose equivalent per year for adults; 50 rem (500 mSv) sum of deep dose and committed dose to any organ other than the lens.

Rule text and source
Rule
20.3.4.405(A)
Source
srca.nm.gov

Why this matters, in ORSIF's FAQs

What is the annual eye-lens dose limit in New Mexico?

Yes

15 rem (150 mSv) per year. No lower limit has been adopted, and the 2026 draft keeps 15 rems.

Rule text and source
Rule
20.3.4.405(A)
Source
srca.nm.gov
What it says
(a) a lens dose equivalent of 15 rems (0.15 sievert); and (b) a shallow dose equivalent of 50 rems (0.5 sievert) 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 New Mexico?

Yes

50 rem (500 mSv) shallow dose per year to the skin of the whole body or any extremity.

Rule text and source
Rule
20.3.4.405(A)
Source
srca.nm.gov
What it says
(a) a lens dose equivalent of 15 rems (0.15 sievert); and (b) a shallow dose equivalent of 50 rems (0.5 sievert) 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 New Mexico?

Yes

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

Rule text and source
Rule
20.3.4.412(A)
Source
srca.nm.gov

Why this matters, in ORSIF's FAQs

Dosimeters

When a worker must wear a dosimeter, and where.

When must a worker in New Mexico wear a dosimeter?

YesLess certain

Monitoring is required for adults likely to exceed 10% of the annual limits; minors above 1 mSv deep dose, 1.5 mSv lens or 5 mSv skin/extremity; declared pregnant women likely to exceed 1 mSv; and people entering high radiation areas. Paragraph (5) separately lists individuals working with medical fluoroscopic equipment, which may mean all fluoroscopy workers must be badged; its intent is unclear.

Rule text and source
Rule
20.3.4.417(A)(1)-(5)
Source
srca.nm.gov
What it says
(1) adults likely to receive, in 1 year from sources external to the body, a dose in excess of 10 percent of the limits in Subsection A of 20.3.4.405 NMAC;
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

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

Yes

With an apron, the whole-body badge goes at the unshielded location of highest exposure, typically the collar; the eye badge goes at the neck outside the apron or closer to the eye. A declared pregnant woman needs a second badge at the waist under the apron. Effective dose rules: a single collar badge counts as the deep dose; if that reading exceeds 25% of the limit it may be multiplied by 0.3; with two badges, effective dose = 1.5 × waist badge + 0.04 × neck badge; other methods need department approval. 20.3.6.602(A)(1)(j) also requires a collar badge outside the apron; the draft would delete this.

Rule text and source
Rule
20.3.4.405(C)(1)-(2); 20.3.4.417(A)(5), (C); 20.3.6.602(A)(1)(j)
Source
srca.nm.gov
What it says
when only one individual monitoring device is used and it is located at the neck outside the protective apron, and the reported dose exceeds 25 percent of the limit specified in Subsection A of this section, the reported deep dose equivalent value multiplied by 0.3
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 New Mexico fluoroscopy rooms wear protective aprons or other apparel?

Yes

Staff must be protected by aprons or whole-body protective barriers of at least 0.25 mm lead equivalent, and any body part in the useful beam needs 0.5 mm. For fluoroscopy scatter, under-table scatter must be attenuated by 0.25 mm Pb eq; above the tabletop, staff must be 120 cm from the beam center or behind 0.25 mm Pb-eq drapes or panels in addition to the apron. The Department may require additional devices. No thyroid shield or eyewear requirement was found. The draft requires a sufficient number of protective apparel to be available.

Rule text and source
Rule
20.3.6.602(A)(1)(e); 20.3.6.604(I)
Source
srca.nm.gov
What it says
staff and ancillary personnel shall be protected from the direct scatter radiation by protective aprons or whole body protective barriers of not less than 0.25 mm lead equivalent;
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Does New Mexico require protective aprons to be inspected?

No

No current requirement. The pending 20.3.6 draft would require annual integrity evaluation and lead-equivalence labeling of all protective apparel and auxiliary shields, without specifying the method. This is proposed, not in force.

Rule text and source
Rule
proposed 20.3.6.602(A)(9) (February 2026 draft and EIB 26-54 version)
Source
env.nm.gov
What it says
All protective apparel and auxiliary shields shall be evaluated annually for integrity and clearly labeled with their lead equivalence.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

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

UnclearLess certain

Engineered radiation protection systems are not addressed by name. The rules allow whole-body protective barriers of at least 0.25 mm Pb eq as an alternative to aprons; drapes, panels and curtains under 604(I)(2) are in addition to the apron. The draft would replace 604(I) with 21 CFR 1020.32. No bill or rule like Arizona's or Illinois's was found.

Rule text and source
Rule
20.3.6.602(A)(1)(e)(ii); 20.3.6.604(I)(2)
Source
srca.nm.gov
What it says
the radiation has passed through not less than 0.25 mm lead equivalent material (e.g., drapes, Bucky-slot cover, sliding or folding 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 New Mexico?

In partLess certain

Licensed practitioners (medicine, dentistry, podiatry, chiropractic, osteopathy) need no imaging license. Students may operate under supervision. NMED-licensed radiographers work under a licensed practitioner's supervision, and radiologist assistants (ARRT RRA) work under a radiologist. Limited-practice licensees may not use fluoroscopy. RNs may not perform ionizing procedures unless licensed. PAs and NPs are not licensed practitioners, and no EIB-approved certification program for them was found.

Rule text and source
Rule
20.3.20.7, 20.3.20.100, 20.3.20.310 NMAC; NMSA 61-14E-7
Source
srca.nm.gov
What it says
perform procedures outside their scope of practice including, but not limited to procedures involving the use of contrast media, fluoroscopic equipment, mammography, computed tomography,
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

What training or credentials does New Mexico require to operate fluoroscopy equipment?

In partLess certain

Technologists need an ARRT credential for licensure (24-month licenses; continuing education follows the credentialing organization; limited licensees need 24 Category A hours). No separate fluoroscopy permit or set training hours were found. No physician fluoroscopy training requirement was found in NMED rules (Medical Board rules not checked). Registrants must ensure operators are adequately instructed. The draft adds that operators meet department qualifications.

Rule text and source
Rule
20.3.20.300,.301,.330 NMAC; 20.3.6.602(A)(1)(b)
Source
srca.nm.gov
What it says
must comply with all continuing education, continuing competency, and registration requirements of the credentialing organization for which they hold a credential or certification.
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 rule20.3.4.404 amendment (program review with all employees)

    Adopted (May 1, 2024)

    Requires the radiation protection program to be covered with all employees before beginning their job duties and annually thereafter.

    Source: srca.nm.gov

  • Proposed ruleEIB 26-54 (R): NMED petition to amend 20.3.1, 20.3.2, 20.3.3, 20.3.4, 20.3.6 and 20.3.20 NMAC

    Public hearing Nov 6, 2026, 1 p.m., Roundhouse, Santa Fe and online; comments accepted until the hearing closes

    Rewrites 20.3.6 as 'Medical Diagnostic and Interventional X-ray and Imaging Systems': adds fluoroscopically guided interventional (FGI) provisions, medical-event reporting, CR/DR QC, annual apron integrity evaluation and a radiation safety program requirement; incorporates 21 CFR 1020.30-.32; deletes the existing fluoroscopy and scatter-control text and the collar-badge text. Makes a 20.3.4.453 citation correction (dose limits and ALARA unchanged) and updates 20.3.20 credentialing organizations.

    Source: cloud.env.nm.gov

1 other item the research logged (radiation therapy, industrial machines, fees and other subjects)
  • Other20.3.4 reference error correction reviewed by NRC

    NRC reviewed as final; no 2026 amendment shown in the official online 20.3.4 (May 1, 2026)

    Correction of a regulatory reference error in 20.3.4 NMAC, submitted April 14, 2026; possibly the same 20.3.4.453 fix pending before the EIB.

    Source: nrc.gov

Also worth knowing

  • New Mexico puts fluoroscopy-specific dosimetry (badge placement and effective-dose formulas) directly into its Part 4 standards.
  • The pending rewrite would replace NM's own fluoroscopy scatter-control rule (604(I)) with FDA performance standards and drop the Department's explicit power to require additional protective devices where staff could reach a quarter of the limit.
  • The 2024 amendment requires covering the radiation protection program with all employees at hire and annually.
  • RCB reports more than 2,000 registered machine facilities.
  • No 2025-2026 NM bills on fluoroscopy or apron alternatives were found; the 2026 memorials SM27 and HM55 concern downwinder compensation (RECA).

What ORSIF could not confirm

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

  • What the EIB adopts after the Nov 6, 2026 hearing on EIB 26-54 and when it takes effect; the full petition could not be opened, and RCB-posted drafts may differ from it.
  • Whether 20.3.4.417(A)(5) requires badges for all fluoroscopy workers regardless of the 10% threshold (ask RCB at RCB.XRAYMachines@env.nm.gov).
  • Whether the 2026 20.3.4 correction described by the NRC is the same 20.3.4.453 fix still pending before the EIB.
  • Whether any board has an EIB-approved imaging certification program that would let PAs or NPs operate fluoroscopy (check MIRTAC minutes and Medical Board rules, 16.10 NMAC).
  • Physician fluoroscopy training requirements in Medical Board rules or hospital credentialing were not checked.
  • Whether RCB would treat engineered radiation protection systems as 'whole body protective barriers'; no guidance was found.
  • Whether the draft 20.3.6 objective's 'As Low As Reasonably Possible (ALARA)' wording will be corrected before adoption.

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.
  • 4 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
ARRT
American Registry of Radiologic Technologists
FGI
Fluoroscopically guided interventional
All 18 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.