How to Run Digital Concrete X-Ray Legally in the U.S.: Compliance, Registration, RSO, Training & Jobsite Controls

Digital Concrete X-Ray Compliance in the U.S.

A plain-English guide for coring & GPR companies that want to run digital concrete x-ray legally, confidently, and profitably

If you’ve built your business around GPR, you’re used to a world where “best practice” is mostly industry-driven: train your crew, calibrate your equipment, document your markouts, and manage client expectations.

Digital Concrete X-Ray is different for one reason: it’s regulated.

That doesn’t mean it’s complicated by default. It means it’s structured. Regulators want to see that your company can operate safely, predictably, and with clear accountability—especially on active construction sites where conditions change and people move through the work area.

This guide from Radii-x Inspections is written for owners and managers evaluating portable concrete xray as a new service line (or considering buy concrete xray system options), and it answers a practical question:

What does compliance mean in normal terms, and what does it take to operate legally and confidently in your state?

Before we start, one important note:

This article is general guidance, not legal advice. Requirements vary by state and by how the equipment is used. Before you operate, your obligations must be confirmed with your state radiation agency. Radii-x supports customers through that confirmation process and provides state-specific checklists, document templates, and training plans aligned to open-beam concrete X-ray work—whether you’re adding xray for concrete slabs, expanding into xray construction, or launching xray inspection for concrete as a dedicated service.

First: “X-Ray” is not the same as “Industrial Radiography”

A lot of confusion comes from one word: radiography.

In many conversations, “industrial radiography” means gamma radiography (sealed radioactive sources like Ir-192 or Co-60). That world typically involves much stricter controls, special licensing structures, and a long history of incidents that shaped the regulations.

Digital Concrete X-Ray (portable open-beam xray generators) is different. There’s no radioactive material. When the unit is off, it’s not emitting. That difference matters—but it doesn’t mean “no rules.” It usually means the compliance path is:

registration + program + training + jobsite controls

—not “gamma radiography licensing.”

So the right mindset is:

This is manageable compliance—but it must be done deliberately.

The 5 compliance elements (the owner’s mental model)

Across most states, a compliant operation comes down to five practical elements:

State registration (company + machine)
Radiation Safety Officer (RSO) / program ownership
Written radiation safety procedures (the binder you can defend on site)
Training & certification (radiation safety + operator competency)
Field controls (how your crew actually runs xray on a live site)

Let’s walk through each element in plain English—and show where states can differ.

Element 1 — State registration: What it is, what you register, and who you register with.

What “registration” means. (plain English)

Registration is the state’s way of saying:

“We know who you are.”
“We know what machine you have.”
“We know where it’s based.”
“We know you have a program to operate it safely.”

In most states, you register the company and list the radiation-producing machine (your X-ray generator). That includes many categories of concrete xray equipment, whether you call it a concrete xray scanner, concrete xray scanner, xray concrete scanner, xray concrete scanner, or a concrete xray device. Some states also care about “use locations,” “mobile use,” or where records are kept.

How long does it usually take?

It depends on the state and how complete your package is. Some states move fast once your paperwork is clean; others take longer. The big variable isn’t “X-Ray vs GPR”—it’s how organized your submission is.

Who does what? (where Radii-x fits)

Radii-x typically supports registration by providing:

the documentation framework (SOPs, templates, forms, program structure)
state-aware guidance for what to submit
help preparing the package so it doesn’t bounce back for missing pieces

You (the owner) typically provide:

company details
responsible contacts
operational addresses
payment + signatures

Registration Examples (showing real differences)

Example A — California (structured portal + specific state process)

California regulates xray machines through CDPH’s Radiologic Health Branch (RHB), with an online portal and state-specific expectations. The state is explicit that you register with them (not “use another state’s registration”). This is relevant whether you’re registering a construction xray machine, floor xray equipment, or a floor xray machine used for slab inspections.

Agency: California Department of Public Health (CDPH) — Radiologic Health Branch (RHB)
Registration page: CDPH RHB Radiation Machine Registration

Example B — Florida (clear “xray machines” program and forms)

Florida’s Department of Health has a dedicated Ionizing Radiation Machines (X-Ray) program with a registration form and compliance/inspection structure. This applies to xray for concrete scanning workflows and the non destructive testing xray concrete category.

Agency: Florida Department of Health — Ionizing Radiation Machines (X-Ray)
Program page + forms: FL DOH X-Ray Program

Example C — Texas (certificate of registration + defined form set)

Texas DSHS runs xray registration under the Radiation Control Program and uses defined forms (including an RSO form in their system). This is common for companies evaluating concrete xray equipment for sale listings and then setting up portable field operations.

Agency: Texas Department of State Health Services (DSHS) — Radiation Control / X-Ray Machines
Program hub: Texas DSHS X-Ray Machines and Services
Forms: Texas pages list forms like the application and an RSO form

The takeaway: Registration is “normal” almost everywhere, but the shape of it changes. Some states are portal-driven. Some are form-driven. Some are certificate-driven. Your job is not to guess—it’s to submit a clean, state-correct package.

Element 2 — RSO and Responsibility: Who “owns” the Program

Who Is An RSO? (in real business terms)

An RSO (Radiation Safety Officer) is the person the state expects to be able to answer:

“What’s your safety program?”
“How do you control the work area?”
“How do you train and authorize operators?”
“How do you track monitoring and records?”
“What happens if something goes wrong?”

Think of it like your radiation safety superintendent, plus paperwork authority.

The key nuance: some states want an “RSO on paper,” others want an “RSO with deeper qualification”.

This is where real variation shows up:

Some states treat the RSO as a designated responsible person who ensures procedures exist and are followed.
Some states expect a higher bar in practice—stronger competency, deeper oversight, and a more formal safety culture—even if you’re using an xray generator (not gamma radiography).

What Radii-x does here (important)

Radii-x doesn’t just provide templates. We support the RSO pathway:

We train your internal lead on what “being the RSO” means day-to-day.
If your state expects a higher-level credential structure or a specific compliance approach, we help you choose the right path (internal RSO, external support, or state-acceptable alternatives).
We help align the RSO role with jobsite reality—so the program is executable, not theoretical.

State examples (kept simple)

Utah: expects a clear, designated program owner and disciplined execution.
Texas: more formal administrative structure that typically pushes stronger documentation habits.
New York: strong example of “program accountability” over “magic cards”—compliance is demonstrated through program quality, records, and execution.

The takeaway: Your biggest compliance risk isn’t the machine—it’s unclear responsibility. Once the RSO role is real (not just a name on paper), everything else becomes simpler.

Element 3: Written Radiation Safety Procedures (your inspection-ready “binder”)

If registration is what makes you legal to operate, the written radiation safety procedures are what make your operation repeatable, defensible, and inspection-ready—especially when you’re using a concrete xray machine / concrete xray machine or a concrete xray scanner on active sites.

Most compliance issues don’t come from bad intentions. They come from inconsistency: one crew does it one way, another crew improvises, logs go missing, boundaries get sloppy when the site is busy, and suddenly you can’t prove what happened. Regulators care less about your marketing claims and more about one thing:

Do you have a written program—and does your crew actually follow it?

What “written radiation safety procedures” really means.

In practice, this is your jobsite binder (digital or physical) that outlines:

how you set up and operate the xray system on active construction sites
how you establish and control the work area during exposures
how you perform and document surveys/verification (as required by your state/program)
how you manage radiation monitoring/dosimetry
how you secure and store equipment
what records you keep and how long you keep them
what you do if something changes or goes wrong (boundary breach, equipment issue, unexpected access)

This isn’t a “medical X-ray manual.” It’s a construction workflow program for portable open-beam concrete X-ray—including ndt concrete xray / non destructive testing xray concrete use cases.

What inspectors and GCs actually want to see?

On a real jobsite, the questions are simple:

“Who is responsible for this program?”
“How do you keep people out during exposures?”
“Where are your procedures?”
“Show me your logs.”
“How do you train and authorize operators?”
“How do you monitor and document safe operation?”

A well-built binder answers those questions immediately—without debate.

How Radii-x makes this operational. (not theoretical)

Many companies struggle because procedures exist, but they aren’t followed consistently because job sites are chaotic.

Radii-x bridges that gap by tying your procedures to a step-by-step workflow and a logbook process inside the Radii-x software. The intent is simple: the team follows a consistent sequence, and the documentation is created naturally as part of the job—not as an afterthought.

That’s how you avoid the classic failure mode: “We did everything right… but we can’t prove it.”

Program examples (two states with different “feel”)

Example: Utah (clarity + disciplined documentation)

Utah rewards programs that are clear, available, and aligned with field behavior—structured procedures and consistent records.

Example: Florida (plain-English, inspection-ready framing)

Florida often communicates requirements in practical, owner-friendly terms: the program must exist, be implemented, and be ready for inspection.

Element 4: Training & Certification (what “training” actually means)

Most owners hear “training” and assume it means one course.

In reality, a clean rollout typically includes two layers—plus practical on-site ramp-up once equipment arrives. This applies whether you’re operating a rebar xray machine / rebar xray machine, a concrete slab xray machine, or a general xray machine for concrete across multiple job types.

Layer 1: Radiation Safety Training (meets state expectations)

This layer covers the “why” and the safety fundamentals:

radiation basics in jobsite terms (not medical theory)
ALARA (time, distance, shielding) applied to construction sites
controlled area discipline and boundary control
monitoring/dosimetry responsibilities
emergency steps and incident response
recordkeeping expectations

How Radii-x supports this: We can deliver this online, or—depending on state expectations—refer you to a compliant domestic provider and help you document it correctly.

Layer 2: Operator Training (How to run Digital Concrete X-Ray for concrete work)

This is the “make your crew job-ready” layer:

equipment setup, positioning, and exposure workflow
controlled area setup in real buildings (not classroom scenarios)
survey/verification workflow and documentation habits
image capture, quality control, and field troubleshooting
interpretation fundamentals for concrete (rebar, PT, conduits, voids)
reporting workflow and what must be documented

Radii-x operator training: We provide a 40-hour (5-day) operator-focused program designed specifically for concrete workflows—so your team can run the system professionally whether you call it xray machine construction, xray construction, or a construction xray machine in day-to-day conversations.

The On-site Reality: The first few days matter most

Even with formal training, the first real jobs are where discipline is built. That’s why successful rollouts include:

a few days of on-site setup + training once equipment arrives
first-job readiness coaching: workflow under constraints, GC communication, boundary control, and documentation habits

Training Examples (how state expectations can vary)

Example: Texas (structured training expectations)

Texas is a strong example of a more formal training environment—where structured documentation and industrial-style discipline matter.

Example: Virginia (OJT-heavy expectations)

Virginia illustrates that some states lean heavily on on-the-job training (OJT). That affects staffing and timeline because experience must be built deliberately.

Example: Illinois (company-based compliance mindset)

Illinois is a good reminder that even if the state doesn’t issue an individual “radiographer card” for generator work, your company still owns training quality and documentation. Compliance is demonstrated through your program and records.

Element 5: Field Controls — What happens on the jobsite

This is where compliance becomes real.

A professional xray operation is not defined by paperwork. It’s defined by whether your crew can run a predictable routine—every time—even when the site is busy and everyone wants it done “right now.” This matters for any xray kit for concrete style workflow, and especially for operators doing xray concrete for rebar verification in congested slabs.

What field controls include:

Field controls are the practical actions that prevent unintended exposure and create defensible documentation:

controlled area setup + postings + physical boundary control
access control (someone owns the boundary during exposure)
surveys/verification workflow when required (measured and documented)
monitoring/dosimetry compliance
jobsite records available and complete
secure storage and transport discipline
staffing rules where applicable

What a clean jobsite flow looks like:

A realistic, repeatable routine looks like this:

You align with the superintendent on exposure windows.
You set the controlled area (cones/tape/signage).
You clear the area and confirm control.
You perform the exposure intentionally (short and controlled).
You release the area and normalize site operations.
You complete the log entry and secure the equipment.

A disciplined workflow keeps the job moving and builds trust with GCs—because it’s predictable.

Field controls examples (three states, three different lessons)

Example: Oregon (measurement-based boundaries + formal authorization culture)

Oregon is a strong example of a state culture that does not like guesswork. Boundaries are expected to be justified, verification documented, and authorization treated formally.

Example: Ohio (strict exception: staffing + monitoring discipline)

Ohio is the “plan for it” example. Some jurisdictions have stricter expectations around monitoring and staffing on temporary job sites. The takeaway isn’t fear—it’s design: build a program strong enough that strict states don’t force a last-minute operational redesign.

Example: California (baseline jobsite discipline + records)

California reinforces the fundamentals: controlled area, access control, secure storage, and consistent documentation. It’s the “do the basics correctly every time” model.

How long does it take to become operational? (A realistic 16-week rollout)

Most coring companies become operational in about 16 weeks when they follow a structured rollout (timing varies by state processing and equipment lead times). Here’s a realistic path that matches how this is typically launched with Radii-x:

Weeks 1–2 — Intro + fit check

Intro call: your use cases, constraints, business goals
Live demo: end-to-end workflow, what xray solves vs GPR, jobsite expectations

Weeks 3–4 — State-specific compliance plan

Confirm your target state(s) and operating model
Build your state-specific checklist: registration path, RSO path, required docs, training approach
Start assembling the registration package (company info + equipment details + program framework)

Weeks 5–6 — Program build (binder + software workflow)

Finalize written radiation safety procedures and jobsite workflow
Configure logbook and step-by-step process in Radii-x software
Prepare your “jobsite-ready” documentation set (what you carry and what you store centrally)

Weeks 7–8 — Radiation safety training (compliance layer)

Radiation safety course delivered online or via domestic provider (state-dependent)
Document completion, roles, and responsibilities (RSO + operators)

Weeks 9–10 — Operator training (capability layer)

40-hour (5-day) Radii-x operator training for concrete workflows
Interpretation fundamentals + reporting discipline + routine rehearsal

Weeks 11–12 — Order confirmation + registration submission progress

Confirm configuration and lock order / manufacturing timeline
Submit or finalize registration materials (state-specific), address agency questions quickly
Build internal readiness: staffing plan, scheduling plan, job types to start with

Weeks 13–14 — Equipment delivery window + readiness prep

Prepare storage/security, transport plan, and jobsite kit
Pre-schedule first jobs suited for rollout (controlled environments)

Week 15 — On-site setup + field training

Equipment setup on site
A few days of real jobsite training: boundary control, workflow under constraints, GC communication, documentation habits
First-job readiness confirmation

Week 16 — Go-live

Begin delivering compliant work
Review early jobs, tighten checklists, standardize logs, and scale responsibly

Bottom line: If you want a predictable launch, treat this like rolling out a new service line—not buying a tool. The 16-week plan keeps compliance, training, and field execution aligned.

FAQ — Digital Concrete X-Ray Compliance (U.S.)

Do I need an NRC license to run a portable concrete X-ray system?

Usually, no—portable X-ray generators are typically regulated through state radiation control / X-ray machine programs, not the NRC framework that people associate with sealed radioactive sources. The key is registering correctly with your state agency and operating under written procedures, training, and jobsite controls.

Do I need an RSO to operate a concrete X-ray scanner?

In most cases, yes—you should expect to designate a Radiation Safety Officer (RSO) or responsible person who owns the program, training records, monitoring, and jobsite procedures. Even when a state doesn’t issue “RSO licenses,” inspectors still expect a real person accountable for the program.

Is Digital Concrete X-Ray the same as industrial radiography (gamma)?

No. “Industrial radiography” often refers to gamma/sealed-source radiography (radioactive material). Digital Concrete X-Ray typically refers to a tube-based X-ray generator that emits only when energized. The regulatory approach is often different, but it’s still regulated and must be operated under a compliant program.

What paperwork should my crew have on site?

At minimum, be ready to show: proof of state registration (or authorization), your written radiation safety procedures (binder), operator training/authorization records, required logs, and any monitoring/survey documentation your program requires. The goal is simple: if asked, you can prove you controlled the work and followed your procedures.

How big is the controlled area on a jobsite?

There is no single “one-size” distance. The controlled area is established by your procedures and the exposure conditions, and in many states it must be justified by measurement/verification when required. The practical requirement is consistent: keep unauthorized people out during exposure, and document your control process.

Do I need a survey meter and radiation surveys?

Many programs and states expect a survey meter and documented surveys, especially for open-beam portable work. Some jurisdictions are explicit that fixed-distance assumptions without verification aren’t acceptable. The safest approach is to plan for measured verification as part of your standard jobsite workflow.

Do operators need personal dosimetry badges?

Often, yes. Many states expect personnel monitoring (badges) for operators, and some states are stricter about how dosimetry is issued, worn, reviewed, and recorded. Your RSO should own the process and keep records inspection-ready.

Does running X-ray shut down the whole floor?

Not necessarily. Most sites don’t require a full shutdown—what’s required is controlled access during exposure. With a disciplined routine (set boundary → clear → expose → release → log), you can run short exposure windows and coordinate smoothly with the superintendent and trades.

How long does it take to become operational?

A realistic rollout is about 16 weeks when done properly (timing varies by state processing and equipment lead times). The sequence is usually: state plan + registration prep → procedures/binder + software logbook → radiation safety training → operator training → on-site setup and first-job coaching → go-live.

What’s the fastest way to know what applies in my state?

Start with the state agency’s official X-ray machine program pages, then build a state-specific checklist that covers registration, RSO, written procedures, training, and jobsite controls. If you want a faster path, Radii-X can map the steps for your exact state(s) and operating model and provide the templates and training plan to execute it.

Final note

Digital Concrete X-Ray compliance is not one intimidating rule. It’s five practical systems that make your work safe, repeatable, and defensible. The fundamentals are consistent, but the details vary by state—especially around registration workflows, training expectations, and field controls.

If you want clarity for your exact state(s) and business model, the fastest path is a structured plan: state-specific checklist, RSO pathway, binder package, training sequence, and a go-live timeline. That’s the foundation for running a professional concrete xray service line—whether you’re comparing concrete xray machine price, evaluating a concrete xray system, planning to purchase concrete xray, exploring buy concrete xray system, reviewing concrete xray equipment for sale, or selecting concrete xray equipment for a new division.