[Intl_DxMedPhys] Are shielding surveys for replacements required?

[Nima Kasraie]

Hi Mike,

I looked thru it. It didn’t find anything specifically about fluoro rooms being upgraded needing a radiation shielding survey performed.  That one passage about “Any changes in design or
shielding which affects radiation exposure levels adjacent to those rooms, requires prior approval by RC” is confusing because it starts out with Radiation Therapy. And then, I thought RC isn’t involved with DX?

All the passages I’ve found are written in a general tone or way that leaves room for interpretation.

It seems the only thing that can be construed in the regs is (as Laura mentioned) writing a statement in your reports that the dose to the public will be lower than a certain amount.

But do you necessarily need a survey measurement for that (the way NCRP 147 says)?



Nima


P.S. I didn’t find the JC document that mentions fluoro either. It’s CT and NM , but not fluoro?


From: Mike Nimmo <mike.t.nimmo at gmail.com>
Sent: Monday, September 8, 2025 2:13 PM
To: Nima Kasraie <Nima.Kasraie at UTSouthwestern.edu>
Cc: intl_dxmedphys_wd_osu_list at lists.osu.edu
Subject: Re: [Intl_DxMedPhys] Are shielding surveys for replacements required?

Hi Nima, It is in the Title 25 Texas Administrative Code Chapter 133, Hospital Licensing rules. Attached. Thanks, On Mon, Sep 8, 2025 at 1: 38 PM Nima Kasraie via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list@ lists. osu. edu> wrote: 

Hi Nima,

It is in the Title 25 Texas Administrative Code Chapter 133, Hospital Licensing rules. Attached.

Thanks,

On Mon, Sep 8, 2025 at 1:38 PM Nima Kasraie via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>> wrote:
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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