[Intl_DxMedPhys] Are shielding surveys for replacements required?

[Laura Flowers]

Nima - Texas inspectors are issuing violations through 289.231 for "public
dose surveys". They are wanting to see a public dose measurement or
statement for all equipment. This can be satisfied for your fluoro/ct rooms
by structural shielding designs and integrity surveys after construction.
(If you replace it with a similar machine you can re-do the shielding
design for the new machine, and then do an integrity survey after
installation to make sure no punctures were made). (Area monitors will show
your yearly exposure, but they are wanting you to prove that a member of
the public will not be exposed to 2mR in any one hour)

On Mon, Sep 8, 2025 at 2:38 PM Ryan Fisher via Intl_dxmedphys_wd_osu_list <
intl_dxmedphys_wd_osu_list at lists.osu.edu> wrote:

> Does TJC require that for fluoro? The original language was specific to
> just CT / PET / NM services, though I’m having trouble tracking down the
> replacement mentioned in this table. I can’t help on TX regs, but Ohio has
> the following, with the
>
> Does TJC require that for fluoro? The original language was specific to
> just CT / PET / NM services, though I’m having trouble tracking down the
> replacement mentioned in this table.
>
>
>
> I can’t help on TX regs, but Ohio
> <https://urldefense.com/v3/__https://codes.ohio.gov/ohio-administrative-code/rule-3701:1-66-02__;!!KGKeukY!1DTfNQ9aFrMNX2qqHFnZN8HMkxT2vuiHMvzBZX0G1K-mPje7a-8AoUoAy091zr2pYY84VjuDdvZc697Ba9kCstureKt3fuGtf5EE4YXwa93e$>
> has the following, with the highlighted bit giving us the flexibility to
> not redo surveys if nothing changed.
>
>
>
> Ohio regs are basically just CRTL+V the CRCP SSRs, so presumably a decent
> number of states have similar carveouts.
>
>
>
>
>
> Ryan
>
>
>
>
>
> *From:* Intl_dxmedphys_wd_osu_list
> <intl_dxmedphys_wd_osu_list-bounces+rfisher1=metrohealth.org at lists.osu.edu>
> *On Behalf Of *Nima Kasraie via Intl_dxmedphys_wd_osu_list
> *Sent:* Monday, September 8, 2025 2:38 PM
> *To:* intl_dxmedphys_wd_osu_list at lists.osu.edu
> *Subject:* [Intl_DxMedPhys] Are shielding surveys for replacements
> required?
>
>
>
> *STOP!*
>
> *THIS IS AN EXTERNAL EMAIL*
> *This email was originated outside of the MetroHealth System*
>
> *Take a 3-second pause and ask yourself the following questions:*
>
> *1. Who is sending me this email? Do I know who this is?*
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> *3. Why is there a link in the email? Do I trust this link?*
>
>
>
> *THINK Before You Click the Link*
>
> Hi all, If you replace a fluoro room with a similar model and vendor with
> no changes to room shielding and walls, do you still need to do a shielding
> survey, legally speaking? TJC says yes. But what about the states? For
> example, in Texas, I
>
> Hi all,
>
>
>
> If you replace a fluoro room with a similar model and vendor *with no
> changes to room shielding and walls*, do you still need to do a shielding
> survey, *legally speaking*?
>
>
>
> TJC says yes.
>
>
>
> But what about the states?
>
>
>
> For example, in *Texas*, I find no mention of the state regs where they compel
> a shielding survey for diagnostic X-ray/fluoroscopy rooms. It’s not in TAC
> 289.227, nor any of the adopted rules I could find.
>
>
>
> But if the state doesn’t ask for it, can they expect a post-installation
> shielding confirmation—especially for high-dose fluoro rooms—even if that
> expectation isn't explicitly stated in 227?
>
>
>
>
>
> I find it hard to accept that the state wouldn’t have any specific
> language on this issue.
>
>
>
>
>
>
>
> Nima
>
>
>
>
> ------------------------------
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-- 

*Laura S. Flowers, Ph.D., DABR, DABSNM*
*Trinity Physics Consulting, LLC*
*(936)544-0952*
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