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Requirements When Using Handheld Analytical X-Ray Equipment

This document outlines the requirements for using handheld X-ray equipment in Pennsylvania, including registration with the Department of Environmental Protection, exemption requests, training, labeling, dosimetry use, and developing radiation safety programs. Handheld X-ray fluorescence analyzers must be registered within 30 days of acquisition and users must apply for an exemption due to the lack of required safety interlocks. Operators must be trained, safety checks performed annually, operating and emergency procedures documented, radiation exposure records maintained, and radiation safety programs implemented and reviewed yearly.

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72 views2 pages

Requirements When Using Handheld Analytical X-Ray Equipment

This document outlines the requirements for using handheld X-ray equipment in Pennsylvania, including registration with the Department of Environmental Protection, exemption requests, training, labeling, dosimetry use, and developing radiation safety programs. Handheld X-ray fluorescence analyzers must be registered within 30 days of acquisition and users must apply for an exemption due to the lack of required safety interlocks. Operators must be trained, safety checks performed annually, operating and emergency procedures documented, radiation exposure records maintained, and radiation safety programs implemented and reviewed yearly.

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Requirements when using Handheld Analytical X-Ray Equipment

With the advancement in technology, one of the most significant trends in the X-ray instrumentation
market has been the emergence of handheld battery-powered X-ray fluorescence (XRF) analyzers.
Analyzers are used in many applications, such as a screening tool for lead, mercury, cadmium, chrome,
and other elements in products. These devices offer greater detection capabilities and are less
expensive than bench equipment. The devices using X-ray tube sources are inherently safer than their
counterparts using radioactive sources that are subject to licensing and hazardous material
transportation regulations.
The popularity of handheld units is driven by their portability and their ability to analyze, identify and
characterize a wide range of elements rapidly, along with the fact that little technical expertise is
needed to operate them. Nevertheless, since these devices produce ionizing radiation, it is imperative
that radiation safety requirements be followed. This fact sheet offers a review of the Pennsylvania
regulations and requirements.
Registration of X-Ray Equipment
By regulation under 25 Pa. Code Chapter 216.2, handheld units that utilize an X-ray tube must be
registered as radiation-producing machines with the Department of Environmental Protections
(department) Bureau of Radiation Protection within 30 days of acquisition.
Exemption Request for Operation
An important safety requirement applies when using these devices. Because most handheld openbeam units do not have a safety device (interlock) as required by Pa. Code Title 25, Chapter 227.11a,
the registrant is required to apply to the department for an exemption from this regulation prior to use.
Proper training in the operation of this device is paramount. But other considerations also need to be
adhered to, such as:

Mandated training provided to the operators and documented records must be maintained.
25 Pa. Code Chapter 227.14
Safety device inspection and checks, e.g., lights and LCD readouts, shall be performed at least
annually and documented for review by the department. 25 Pa. Code Chapter 227.12a(e)
Operating procedures shall be written and available to operators of the analytical equipment.
25 Pa. Code Chapter 227.13a(a)
Emergency procedures shall be written and available to operators of the analytical equipment.
25 Pa. Code Chapter 227.13a(d)
A written radiation safety program based on the radiation protection principles that are as low as
reasonably achievable (ALARA) shall be developed, documented and implemented. The
radiation protection program shall be reviewed at least annually. 25 Pa. Code Chapter 219.5
and 10 CFR 20.1101
Analytical X-ray equipment shall be labeled CAUTION RADIATION THIS EQUIPMENT
PRODUCES RADIATION WHEN ENERGIZED or words having a similar intent. 25 Pa. Code
Chapter 227.11a(f)(2). Unless the device produces high intensity X-rays, no further labeling is
required.
Personnel dosimeters, preferably finger and/or wrist dosimeters, are required to be worn during
operation. Exposure records shall be maintained by the facility and available to the operator.
The registrant must maintain control of the device at all times to prevent theft or operation by an
unauthorized user. 25 Pa. Code Chapter 219.132

A registrant should apply to the department for exemption by written request to the appropriate regional
office that oversees the facility location. Reference the table below for the appropriate regional
address.
Region
East

Phone

Region Headquarters

Counties Supervised

484-250-5950 2 East Main Street


Norristown, PA 19401

Bucks,
Chester,
Delaware,
Montgomery,
Philadelphia,
Carbon, Lackawanna, Lehigh,
Luzerne, Monroe, Northampton, Pike, Schuylkill,
Susquehanna, Wayne, Wyoming

Central 717-705-4700 909 Elmerton Avenue


Harrisburg, PA 17110

Adams, Bedford, Berks, Blair, Cumberland, Dauphin,


Franklin, Fulton, Huntingdon, Juniata, Lancaster,
Lebanon, Mifflin, Perry, York, Bradford, Cameron,
Centre, Clearfield, Clinton, Columbia, Lycoming,
Montour, Northumberland, Potter, Snyder, Sullivan,
Tioga, Union

West

Allegheny, Armstrong, Beaver, Cambria, Fayette,


Greene,
Indiana,
Somerset,
Washington,
Westmoreland, Butler, Clarion, Crawford, Elk, Erie,
Forest, Jefferson, Lawrence, McKean, Mercer,
Venango, Warren

412-442-4000 400 Waterfront Drive


Pittsburgh, PA 15222-4745

References
Pennsylvania Code Title 25 Regulations, www.pacode.com.
For more information, visit www.depweb.state.pa.us, keyword:
Radiation Protection at 717-787-3720.

Commonwealth of Pennsylvania
www.depweb.state.pa.us

Radiation, or call the Bureau of

Department of Environmental Protection


2910-FS-DEP4233 4/2011

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