[Intl_DxMedPhys] Are shielding surveys for replacements required?

[Mike Nimmo]

Hi Nima,

I think I misunderstood the emphasis of your question on fluoro. I agree
with what everyone else has said, obviously. To my knowledge and
understanding, TJC requires you to follow your state regulations for
fluoro. For a unit replacement where they did not renovate the walls, I
almost always perform a scatter survey, but sometimes I will make a note if
the previous survey was truly adequate that no change in public dose is
expected. I then attach that memo to the previous survey/area monitors
report/etc and file it with the reports for the new equipment.

Thanks,

Mike


On Mon, Sep 8, 2025 at 3:03 PM Nima Kasraie <Nima.Kasraie at utsouthwestern.edu>
wrote:

> 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>
> 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
>
>
>
>
> ------------------------------
>
> *UT** Southwestern*
>
> Medical Center
>
> The future of medicine, today.
>
>
>
> --
>
> Mike Nimmo
>


-- 
Mike Nimmo
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