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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 It is not comprehensive and not always accurate: rules change, and answers may be incomplete, out of date or wrong.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 Vermont Department of Health, Radiological Health Program as the agency that regulates X-ray and fluoroscopy equipment in Vermont. Vermont is a U.S. Nuclear Regulatory Commission (NRC) Agreement State: it has signed an agreement with the NRC to regulate certain radioactive materials itself.

Vermont's Radiological Health Rule Part A (effective January 1, 2024) has its own X-ray ALARA requirement (§ 7.1.2), separate from Part B, which adopts 10 CFR Part 20 by reference. Worker dose limits match the NRC's: 50 mSv whole body, 150 mSv lens of the eye, 500 mSv skin and extremities, and 5 mSv to the fetus of a declared pregnant worker. Staff must be protected by aprons or whole-body barriers of at least 0.25 mm lead equivalent. Apron inspection appears only in non-binding guidance, and engineered protection systems are not directly addressed. Technologists need American Registry of Radiologic Technologists (ARRT) certification, including post-primary certification for cardiac or vascular interventional work. Non-radiologist practitioners need an OPR radiation-competency endorsement unless exempt.

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 Vermont an NRC Agreement State?

Yes

Yes. Per the NRC list (updated 2026-10-29); Part B adopts NRC materials regulations, which fits.

Rule text and source
Rule
NRC list of Agreement States, updated October 29, 2026; Radiological Health Rule Part B, § 1.2.6.6
Source
nrc.gov

Why this matters, in ORSIF's FAQs

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

Yes

Yes. Vermont's Radiological Health Rule (Code Vt. R. 13-140-030), effective 1/1/2024. Part A covers radiation-producing machines: § 7.0 has the protection standards, § 8.0 covers healing-arts X-ray and § 8.13 covers fluoroscopy. Part B covers radioactive materials and adopts 10 CFR Part 20. Part C covers Vermont Yankee.

Rule text and source
Rule
Radiological Health Rule Part A §§ 2.1, 7.0, 8.0, 8.13; Part B § 6.2
Source
healthvermont.gov
What it says
Part A of this Rule establishes standards for the control of ionizing radiation-producing machines for the protection of occupational and public health and safety.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

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

Yes

Yes. X-ray registrants must have a radiation protection program, use procedures and engineering controls to keep doses ALARA, and review the program at least annually.

Where ALARA lives in Vermont: In a shared rule and in X-ray-specific language. The X-ray ALARA requirement is Vermont's own text in Part A § 7.1.2. Separately, Part B adopts 10 CFR Part 20, including § 20.1101, by reference without an edition date. The NRC proposal would affect Part B directly but not Part A. (Part A §§ 2.3, 7.1.2; Part B §§ 1.2.5, 6.2.1-6.2.2)

Rule text and source
Rule
Part A § 7.1.2 (definition in § 3.9)
Source
healthvermont.gov
What it says
The 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 eye-lens dose limit in Vermont?

Yes

0.15 Sv (15 rem), or 150 mSv, per year. Vermont has not adopted the International Commission on Radiological Protection (ICRP)'s 20 mSv.

Rule text and source
Rule
Part A § 7.2.1.2.1
Source
healthvermont.gov
What it says
A lens dose equivalent of 0.15 Sv (15 rem); and … A shallow dose equivalent of 0.5 Sv (50 rem) 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 Vermont?

Yes

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

Rule text and source
Rule
Part A § 7.2.1.2.2
Source
healthvermont.gov
What it says
A lens dose equivalent of 0.15 Sv (15 rem); and … A shallow dose equivalent of 0.5 Sv (50 rem) 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 Vermont?

Yes

5 mSv (0.5 rem) to the embryo/fetus of a declared pregnant worker for the whole pregnancy. The registrant must try to avoid large swings above a steady monthly rate.

Rule text and source
Rule
Part A §§ 7.5.1, 7.5.2
Source
healthvermont.gov

Why this matters, in ORSIF's FAQs

Dosimeters

When a worker must wear a dosimeter, and where.

When must a worker in Vermont wear a dosimeter?

Yes

Dosimeters are required for adults likely to exceed 10% of any adult limit in a year (5 mSv whole body, 15 mSv lens, 50 mSv skin/extremity), for minors above lower thresholds, for declared pregnant workers likely to exceed 1 mSv during the pregnancy, and for anyone entering a high or very high radiation area. The Department may approve alternatives to continuous badging in writing. Dosimeters must be processed by a National Voluntary Laboratory Accreditation Program (NVLAP)-accredited processor.

Rule text and source
Rule
Part A §§ 7.8.1.1-7.8.1.4, 7.8.2
Source
healthvermont.gov
What it says
Adults likely to receive, in 1 year from sources external to the body, a dose in excess of 10 percent of the limits in 7.2.1.
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 Vermont when a protective apron is worn?

Yes

Yes, for machine sources. One badge at the neck outside the apron: if the reading exceeds 25% of the limit, effective dose equivalent = reading × 0.3. Two badges: (waist under apron × 1.5) + (neck × 0.04). The fetal badge goes under the apron at the waist. The non-binding March 2026 guidance conflicts with these placements.

Rule text and source
Rule
Part A §§ 7.2.4.3.1, 7.2.4.3.2, 7.5.4
Source
healthvermont.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% of the limit specified in 7.2.1, the reported deep dose equivalent value multiplied by 0.3 shall be the effective dose equivalent for external radiation
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 Vermont fluoroscopy rooms wear protective aprons or other apparel?

Yes

Aprons or whole-body barriers of at least 0.25 mm lead equivalent are required for staff in the room; the general rule also allows staying 2 m away instead. Fluoroscopy requires an additional 0.25 mm Pb above and below the table unless the person is at least 120 cm from the center of the X-ray field. A person who could be struck by the direct beam needs at least 0.5 mm Pb. Thyroid shields and eyewear are recommended only in guidance.

Rule text and source
Rule
Part A §§ 8.8.1.2, 8.9.4, 8.9.5.1, 8.13.5.1-8.13.5.3
Source
healthvermont.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 material.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

Does Vermont require protective aprons to be inspected?

Not foundLess certain

Not found in the rule. Only the Department's non-binding Lead Aprons guidance (March 2026) calls for monthly visual inspection.

Rule text and source
Rule
Rule: not found. Guidance: "X-Ray Facility Tips, Lead Aprons"
Source
healthvermont.gov
What it says
Lead or lead-equivalent aprons and thyroid collars shall be visually inspected for defects at least monthly, and replaced if they are damaged.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

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

UnclearLess certain

Not directly addressed. The rule accepts aprons or whole-body protective barriers but does not define such barriers. The fluoroscopy guidance implies that large mobile shields can substitute.

Rule text and source
Rule
Part A §§ 8.8.1.2, 8.9.5.1.1, 8.13.5.2.2; fluoroscopy guidance (March 2026)
Source
healthvermont.gov
What it says
All personnel not protected by a large mobile shield should wear a well-fitted lead 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 Vermont?

YesLess certain

Use must be by, or under the general supervision of, a Vermont-licensed practitioner. Licensed radiologic technologists may operate. Exempt licensed practitioners need an OPR competency endorsement unless they are ABR-certified radiologists or ABIM-certified interventional cardiologists or electrophysiologists. PA authority is unclear. Delegation to unauthorized staff is barred.

Rule text and source
Rule
Rule Part A §§ 3.28, 8.2.6, 8.2.6.1; 26 V.S.A. §§ 2801(6), 2802, 2803, 2804, 2857; OPR Admin. Rules 2.4
Source
legislature.vermont.gov
What it says
Use of a radiation machine in the healing arts shall be by or under the general supervision of a Vermont-licensed veterinarian, physician, chiropractor, dentist, podiatrist, or other Vermont-licensed health care practitioner authorized to do so within their scope of practice.
This quote was matched word for word to the source page.

Why this matters, in ORSIF's FAQs

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

Yes

Technologists need an ARRT-approved program and ARRT radiography certification, plus post-primary certification for cardiac- or vascular-interventional work, and 24 hours of continuing education (CE) every two years. Endorsed practitioners need an approved radiation-safety course (for fluoroscopy, "Fluoroscopic Safety Explained for Physicians") and must keep fluoroscopy logs. No state fluoroscopy permit or set number of training hours was found.

Rule text and source
Rule
26 V.S.A. §§ 2804, 2812(b)(5), 2821a, 2821b; OPR Administrative Rules Parts 2-3; Rule Part A §§ 7.18, 8.4.1, 8.10.1.2
Source
legislature.vermont.gov
What it says
The Director shall recognize and follow the ARRT and NMTCB postprimary certification process in the following postprimary practice categories: mammography, computed tomography (CT), cardiac-interventional radiography, vascular-interventional radiography, and positron emission tomography (PET).
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.

  • Proposed ruleReforming and Modernizing the NRC's Radiation Protection Framework

    Proposed (NRC) (Jul 15, 2026)

    Would require Agreement States to revise their equivalent of 10 CFR 20.1101(b) to be essentially identical to the NRC's and remove ALARA; in Vermont this would affect Part B.

    Source: federalregister.gov

  • BillAct 119 (2026), OPR professions act

    Signed June 8, 2026

    No change to the radiology chapter found; it changes Board of Medical Practice background checks, including for radiologist assistants.

    Source: legislature.vermont.gov

  • GuidanceDepartment X-ray guidance reissue

    Reissued (Mar 2026)

    The Department reissued its X-ray facility guidance; not a rule change.

    Source: healthvermont.gov

1 other item the research logged (radiation therapy, industrial machines, fees and other subjects)
  • GuidanceOPR Application Instructions for Ionizing Radiation Privileges

    Updated (Feb 2026)

    OPR updated its endorsement instructions; not a rule change.

    Source: outside.vermont.gov

Also worth knowing

  • Fluoroscopically guided interventions require written high-dose policies, skin dose recorded in the chart, and a Radiation Safety Officer dose review at 2 Gy or more; exam records must include the operator's name and be kept 5 years.
  • Monitored workers get a written dose report at least once a year, and former workers can request one.
  • Doses from other employers count against the current year's limit.
  • A Qualified Expert must design room shielding and re-evaluate it when workload rises.
  • The fluoroscopy guidance stresses training for everyone in the room, ergonomics and apron weight, wrap-around aprons, and sharing dosimetry reviews with staff.
  • The guidance uses 'shall' for monthly apron checks that the rule does not require and conflicts with the rule on badge placement.

What ORSIF could not confirm

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

  • Part B § 6.2.1 adopts 10 CFR Part 20 with no edition date, so it is unclear whether a final NRC rule would apply automatically or only after Vermont amends its rule.
  • It is not known whether Vermont commented on the NRC proposal or plans to change Part A § 7.1.2 to match.
  • Whether a physician assistant may actuate fluoroscopy is unsettled.
  • 'Whole body protective barrier' is undefined, so whether an engineered shielding system qualifies in place of an apron needs a Department interpretation.
  • The guidance conflicts with the rule on monthly apron checks and badge placement; it is unclear which the Department enforces at inspections.
  • The OPR rules (2017) still use 'Board' language, and the 2026 'acts affecting statutes' index could not be opened.

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

  • 2 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.
  • 3 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
ARRT
American Registry of Radiologic Technologists
NVLAP
National Voluntary Laboratory Accreditation Program
CE
Continuing education
All 16 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.