In accordance with 105.CMR.120.021, analytical x-ray equipment, including bone densitometers, x-ray crystallography systems, diffractometers, and some scanning electron microscopes (SEM), needs to be registered with the Massachusetts Radiation Control Program (RCP).
The registration form requires that the proposed Radiation Safety Officer (RSO) be identified, and their qualifications need to be listed. A certificate of training for the proposed RSO must be submitted with the registration. The training can be the full 40-hour radiation safety officer training, or something shorter. Safety Partners is now offering an online training module specific to RSOs and users of analytical X-ray equipment! This training takes approximately 1 to 2 hours to complete, depending on a person’s background and experience. It’s recommended initially and annually.
Should your company move, relocation of registered x-ray equipment does not require a new registration as long as the equipment is moving within the same company and remaining under the oversight of the same RSO. The RCP needs to be notified of the move by submitting a letter to them that includes the previously registered location and the new location, a copy of the original registration, and a request that the registration be updated with the new location.
If the equipment is transferred to another company within Massachusetts, it needs to be registered under the new owner and location, and the original registration needs to be closed. If equipment is transferred out of state, the destination state-specific requirements would need to be reviewed to determine if the equipment needs to be registered in that state and if there are any additional requirements.
Remember that filing the registration is not the only requirement! 105.CMR.120.600 stipulates the other requirements for analytical x-ray equipment. These include training, surveys (unless the equipment is exempt), signage, and in some cases, dosimetry.
For additional information on registering your analytical x-ray equipment, and complying with registration requirements, please email us at firstname.lastname@example.org.