Pennsylvania: radiation safety rules for fluoroscopy teams

Yes. Pennsylvania is not on the NRC's list of non-Agreement States. In 2025 it changed its rules after the NRC's periodic review for Agreement States' program compatibility.

25 Pa. Code Chapter 221, "X-Rays in the Healing Arts", covers X-ray and fluoroscopy (fluoroscopy in §§ 221.35a-221.43a; scattered radiation in § 221.42a). It adds to Chapter 219, "Standards for Protection Against Radiation", rather than replacing it. Section 219.5 adopts 10 CFR Part 20 by reference, and § 219.1 applies Chapter 219 to both licensees and registrants. Chapter 221 was last broadly amended effective 2019-01-24 (48 Pa.B. 6791), and the PA Code site lists it as current through 56 Pa.B. 1800 (March 28, 2026).

Yes, indirectly. Section 219.5 adopts 10 CFR Part 20, including the ALARA requirement in 20.1101(b), and § 219.6(3) says "licensee" includes "registrant". Pennsylvania's code does not reprint the ALARA text itself.

Where ALARA lives in Pennsylvania: Only in a rule shared with radioactive materials. The ALARA wording exists only in the shared rule (Chapter 219, through the adopted 10 CFR Part 20 text), which also covers radioactive-materials licensees. An NRC change to 10 CFR 20.1101 could therefore carry over to X-ray registrants. Section 221.11(i) has a narrower X-ray-specific duty to use procedures and equipment that minimize exposure, but it does not use the ALARA term or ALARA's program structure. Whether Pennsylvania's adoption of Part 20 is dynamic or static is unconfirmed. (25 Pa. Code §§ 219.5, 219.6(3), 221.11(i))

5 rem (50 mSv) TEDE per year, from 10 CFR Part 20 as adopted through § 219.5. Minors are limited to 10% of the adult limits.

15 rem (150 mSv) per year, from the adopted federal rule. Pennsylvania has not adopted a lower lens limit; nothing found in Chapter 219 or 221 sets 20 mSv.

50 rem (500 mSv) per year to the skin or any extremity, from the adopted federal rule.

0.5 rem (5 mSv) to the embryo/fetus of a declared pregnant worker over the whole pregnancy, from the adopted federal rule.

The federal threshold applies through § 219.5. Monitoring is required for adults likely to get more than 10% of an annual limit from external sources, and for declared pregnant workers likely to get more than 10% of the embryo/fetus limit (0.05 rem / 0.5 mSv). No Pennsylvania-specific threshold was found.

No Pennsylvania-specific rule on badge location was found; the federal rule only says the assigned dose must be for the part of the body with the highest exposure. Section 219.6(8) lets X-ray exposures be weighted in a manner specified by DEP, so that with DEP approval effective dose equivalent replaces deep dose equivalent. No Pennsylvania text names a two-badge method, National Council on Radiation Protection and Measurements (NCRP) 122, Webster, or a collar location.

Everyone needed for the procedure must be protected by aprons or whole protective barriers of at least 0.25 mm lead equivalent, or stand out of the direct beam with the nearest part of the body at least 2 m from both the tube and the image receptor. Body parts in the useful beam need at least 0.5 mm lead equivalent, measured at 60 kV. Section 221.42a requires shielding against scatter from under and above the table unless the person is at least 120 cm away. Thyroid shields and eyewear are not addressed in the sections reviewed.

not found

Engineered systems used in place of aprons are not addressed by name. Section 221.11(e)(2) accepts "whole protective barriers" of 0.25 mm lead equivalent as an alternative to aprons, but the term is not defined in the text reviewed. Section 221.42a(b)(2) treats drapes, panels and curtains as shielding needed in addition to the apron.

Section 221.35a(b) limits clinical fluoroscopy to: licensed practitioners within their scope of practice (medicine, surgery, dentistry, osteopathy, podiatry or chiropractic); DEP-recognized radiologist assistants under direct supervision; ARRT-certified people (or equivalent) under personal supervision; and residents, radiologist-assistant trainees and student technologists in training, under personal supervision. Auxiliary personnel must also follow 49 Pa. Code (§ 215.24(b)). DEP's FAQ says physician assistants may perform fluoroscopy under an approved contract with a medical provider that lists the procedures, and nurse practitioners only if ARRT-registered. The FAQ also says trained residents and PAs may work under direct supervision, which appears looser than the rule text for trainees.

The registrant must make sure operators and supervisors are trained and competent in the topics listed in § 221.16(a)(1), including fluoroscopic outputs, high-level control and dose management. People who operate or supervise high-risk procedures (skin dose that could exceed 2 Gy) must be certified by a DEP-recognized professional organization. Continuing education is required every 2 years for high-risk procedures and every 4 years for low-risk ones, and high-risk education must cover facility- and unit-specific patient dose management. Records are kept for 5 years. No state fluoroscopy permit or minimum training hours were found. The FAQ lets graduates of accredited programs who are not yet ARRT-certified work under direct supervision for 6 months.