- Installation Notification Requirements in Japan
To install an industrial X-ray inspection system in Japan, specific notifications must be filed with the relevant authorities. The destination for submission depends on whether the entity is a public organization or a private company.
If you are a central ministry, you must notify the National Personnel Authority within 30 days of installation.
If you are a public institution, you need to notify the personnel committee of each prefecture at least 30 days before the scheduled installation.
If you are a private company, you need to notify the Labor Standards Inspection Office of your jurisdiction at least 30 days before the planned installation.
Documents required for notification are
(1) "Notification of installation / relocation / change of machinery" (Form No. 20)
(2) "Radiation Equipment Summary" (Form No. 27)
(3) "Drawing of the Controlled Area" (A diagram indicating the boundaries of the controlled area)
- Do I need an X-ray work chief license to use X-ray equipment in Japan?
Whether a licensed supervisor is required depends on factors such as the leakage dose rate of the X-ray equipment and its duration of use.
The dose limit is 0.1 mSv / week (100 μSv / week) if three months is 13 weeks, and 20 μSv / day if one week is five days.
Assuming a maximum daily operation of 10 hours, a leakage dose rate of 2 μSv/h or less ensures that the radiation level remains below the threshold for a controlled area. Consequently, the area outside the device is not classified as a radiation controlled area, which is a key factor in determining the need for a licensed supervisor.
- Is special training required to operate X-ray equipment in Japan?
Key Regulatory Change in Japan (October 2020)
The Industrial Safety and Health Regulations and the Ionizing Radiation Hazard Prevention Regulations (IRHPR) were partially amended on October 29, 2020, in Japan, introducing an important exemption.
Generally, special training is not required for operators using fully shielded "cabinet-type" X-ray equipment.
Following amendments to the Industrial Safety and Health Regulations and the Ionizing Radiation Hazard Prevention Regulations (IRHPR), an exemption was introduced for equipment featuring a shielded structure designed to prevent any part of the worker's body from entering the interior during irradiation.
This amendment specifically addresses cabinet X-ray inspection systems.
Reference: Measures for Preventing Ionizing Radiation Hazards | MHLW (Japanese)
Revised IRHPR (Effective April 1, 2021)
Article 52-5 The employer shall provide special education on the following subjects to workers engaged in operations involving the handling of X-ray equipment or gamma-ray irradiators (excluding operations involving the use of equipment with a shielded structure designed so that only the controlled area exists inside the equipment and to prevent a worker's entire or partial body from entering its interior during X-ray or gamma ray irradiation; the same shall apply hereinafter in this Article):
1. Knowledge of work procedures related to the handling of X-ray equipment or gamma-ray irradiators.
2. Knowledge of the structure and methods of handling X-ray equipment or gamma-ray irradiators.
3. The effects of ionizing radiation on the living body.
4. Related laws and regulations.
Article 52-5 The employer shall provide special education on the following subjects to workers engaged in radiographic photography using X-ray equipment or gamma-ray irradiators:
1. Procedures for radiographic photography.
2. Knowledge of the structure and methods of handling X-ray equipment or gamma-ray irradiators.
3. The effects of ionizing radiation on the living body.
4. Related laws and regulations.
The requirement for special education excludes operations involving equipment with a shielded structure designed so that only the controlled area exists inside the equipment, preventing worker exposure during operation.
While traditional radiographic work using film requires strict oversight, modern digital X-ray inspection systems (cabinet type) generally fall under this exemption, subject to the interpretation of the specific equipment structure.
- Regulations in Other Regions (Global)
Regulatory requirements vary significantly by country and region. We recommend consulting with your local safety officer or contacting our sales representatives for specific details.
Matsusada Precision's industrial X-ray inspection systems are designed as cabinet X-ray systems with a leakage dose rate of 1 μSv/h or less. In many regions, including the United States (FDA compliance) and Europe, fully shielded systems meeting these specifications often face fewer installation restrictions compared to open-type X-ray sources.
Please note that registration or notification to local authorities may still be required depending on local laws.
Related Technical Articles
- FAQ: Does the revised "Ordinance on Prevention of Ionizing Radiation Hazards" in Japan affect X-ray products?
- The Right Way to Choose appropriate X-ray Inspection System
- Principles of Radiography
- How to use X-ray Inspection System safely
- Explaining the effects of radiation on the human body and the safety of X-ray equipment
- What is the difference between radioactivity, radiation, and radioactive materials?