For all of you process and manufacturing engineers, this is an email that I am sending to a distributor of X-ray and laser equipment who requested it. I am copying Technet both to increase your awareness, or to remind you of the requirements for registration and handling of radiation-generating equipment. Following are the general requirements of the State of Minnesota in regards to Radiation-generating equipment, which can be X-ray machines, XRf equipment, Laser soldering or laser marking machines, laser welding equipment, etc. The requirements are slightly different for different types of equipment, and they vary from state to state within the U.S., and vary wildly outside of the U.S. You need to check and understand what the local requirements are for the locality where the subject machine is being used. There may be other requirements I have not covered here. You need to check your own local regulations concerning this. 1. Controlled Access. The machine must have controlled access. This can be either a key-operated switch that enables the machine to be turned on and off, with control over the location of the key (typically controlled by a Master Key person) or a secure software password that disables itself if the machine is sitting idle. If a key is used, it cannot be left in the keyswitch when the key operator is finished using the machine. The objective is to prevent any untrained and uncertified personnel or outsider from being able to activate the radiation-generating portion of the machine. 2. List of Certified Operators Posted. A list of certified operators shall be posted on the machine. These are operators who may or may not have controlled access, but anyone operating the machine must have passed a Hazardous Radiation Handling class including a written test that is approved by the State of Minnesota (you can get this from OSHA), and must be recertified each year. In addition, there must be a secondary class that they must attend that teaches "in comprehensive detail" how to operate the machine, including the location of all safety features and knowledge of use. 3. Radiation Hazard Warning Labels These must be posted on the front of the machine, or the side of the machine where access to the chamber is made. In addition, black and white striped Hazardous Radiation tape should be on the floor in front of the access door. For pass-through conveyorized machines, both ends must have the tape on the floor. 4. Radiation Leakage Test Performed (for X-ray or XrF equipment) A radiation leakage test must be performed around the entire outside surface of the machine. This can be done by purchasing or leasing a NIST-calibrated Geiger counter, or as part of the maintenance agreement with the machine vendor. However, the dated leakage test results must be posted on the machine where it is easily visible, and must include the method used, the measured radiation, and who performed the inspection. 5. Machine Operation Instructions Posted Comprehensive instructions for operation of the machine shall be posted on the machine. This can be either the operating manuals from the machine vendor or documented instructions written and maintained by the user. 6. Registration of the Radiation Generator In Minnesota, the X-ray tube, laser generator, or other radiation source must be registered with the State, and a copy of the registration should be posted on the machine. When an X-ray machine is deactivated, you want to contact the State or your local regulator to ensure the registration is noted as deactivated, and you want to make a note with the State if the machine is sold or scrapped. I know of more than one process engineer who has spent the better part of a week attempting to trace the equipment, hunting through used equipment warehouses, junkyards, and competitor's facilities attempting to track down the current location of a piece of radiation equipment. The state is required to perform audits on this procedure, and I pity the poor sucker who forgets to de-list the equipment. You want to make sure all of the requirements are in place. If the OSHA people come into your facility, the first thing they look for is radiation equipment. If they find the machine is being operated without the above controls, the result is usually an immediate plant shutdown until all corrective action is finished, followed by expensive fines. I don't want this to happen to anyone, hence this message. 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