Setting up a new x-ray system in Hawaii? The single biggest thing to know going in: the state wants your paperwork filed before you ever install the machine — not after. Here's exactly what that means and how to stay ahead of it.
Hawaii regulates x-ray equipment through the Department of Health's Indoor and Radiological Health Branch (IRHB), Radiation Section — the agency responsible for licensing radiation-producing machines, reviewing shielding plans, and conducting inspections statewide. Unlike some states that give you a grace period after a machine arrives, Hawaii requires facilities to apply at least sixty days before they acquire or begin operating a radiation source. That single detail changes how far in advance you need to start the paperwork.
Here's a complete walkthrough of how licensing works with IRHB, what your facility and your operators each need, and the requirements — shielding, dosimetry, inspections — that come along with owning and running an x-ray system in the islands.
As in every state, Hawaii splits oversight into two distinct tracks:
1. Facility licensing — licensing the location and the actual x-ray equipment with the DOH Indoor and Radiological Health Branch. This is what most of this guide covers.
2. Operator licensure — a completely separate requirement for the people who take or supervise x-rays, licensed through Hawaii's Radiologic Technology Board (RTB). More on this below.
Under Hawaii Administrative Rules, Title 11, Chapter 45 (Radiation Control), anyone acquiring, installing, or using a radiation machine must hold a Radiation Facility License before doing so. That covers:
A related but separate credential — the Radiation Service License — applies to companies and individuals that sell, lease, service, or install radiation machines, or that provide health physics or medical physics services, as well as anyone offering portable x-ray services. If you're buying equipment from a vendor rather than manufacturing or servicing it yourself, you generally only need the facility license; your vendor and physicist are the ones who need the service license on their side.
Here's what actually happens between deciding you need a machine and having a licensed, operational facility — in order, with the reasoning behind each step so you know why it matters and not just what to check off.
| Information | Details |
|---|---|
| Facility / DBA name | Legal name and business structure (Inc., LLC, sole proprietor) of the entity operating the machine |
| Address & contact info | Street address, city, state, zip, phone, and fax for the facility, plus a separate mailing address if different |
| Responsible personnel | Names and contact details for your compliance contact, Radiation Safety Officer, and inspection contact |
| Equipment details | Manufacturer, model number, serial number, manufacture date, location, and intended use for every unit |
| Purpose of use | Diagnostic, screening, therapeutic, industrial, or analytical use category |
| Payment | Check or money order for the license fee — credit cards are not accepted |
This is one of the most commonly missed requirements, mostly because it doesn't show up as a line item on the license application — it's a separate, ongoing obligation under HAR §11-45-39. Every radiation facility in Hawaii, regardless of category, must establish and maintain a written radiation protection program, and it has to be reviewed at least annually, not just written once and filed away.
What the program has to accomplish — the core standard is ALARA (as low as reasonably achievable): written procedures aimed at keeping occupational and public radiation dose as low as practically possible, not just under the legal limit.
You don't have to write it from scratch — IRHB publishes facility-type rule guides (for dental and veterinary facilities, among others) that are explicitly built so a facility can adopt the guide itself as its program, rather than drafting an original document. You can also develop or adopt any program that's equivalent to or better than the published guide.
If you adopt a published rule guide as your program, every employee has to sign an Annual Review and Acknowledgement page — once when they start, and again every year after. This is a specific, checkable item, so keep the signed pages on file rather than relying on a verbal "everyone knows the rules."
Day to day, this program is run by the Person Responsible for Radiation Safety — the same person you name on your facility license application, sometimes referred to elsewhere as your Radiation Safety Officer. Their responsibilities include reviewing periodic dosimetry and exposure reports, confirming no one on staff exceeds occupational dose limits, notifying the Department of Health if someone does, and keeping employees informed of their own annual dose. Because this person is named on your application before you're even licensed, it's worth having your program (or your choice of which published rule guide to adopt) settled before you file, not scrambled together afterward.
This is where Hawaii differs from several other states: the Department of Health requires your shielding design to be submitted to IRHB for review and approval for new or renovated radiation facilities — it isn't left entirely to your physicist's own sign-off, and it isn't a courtesy submission. Two separate, sequential steps come into play here, governed by HAR §11-45-33 and §11-45-34, and it's easy to assume they're the same thing:
Step 1: Shielding evaluation (pre-construction) — Before construction begins on a new or renovated radiation facility, the licensee or applicant must have a qualified medical physicist prepare a written shielding evaluation report. That report has to be submitted to IRHB together with your architectural and electrical plans, and it must document:
Your construction plans, in turn, have to show the source location, beam direction, structural dimensions, the actual lead thickness called out for each barrier, the occupancy classification of every adjoining room, and the distance from the source to each occupied area. Critically, the lead thickness and other shielding specifications built into the room must equal or exceed what the physicist's evaluation calls for — a contractor can always over-build a barrier, just never under-build one relative to the approved numbers.
Step 2: Area radiation survey (post-construction) — Once the room is built and the facility is operational, a qualified medical physicist must conduct (or directly supervise) an area radiation survey within six months of the facility going into operation, to confirm the shielding as actually built meets the standards in the approved evaluation. You then have 30 days after completing the survey to forward the report to IRHB. New surveys are also triggered later on by changes in the number of x-ray machines, changes to workload or exam volume, or repositioning of equipment, walls, doors, or chairs relative to what the original survey assumed. This survey step generally isn't optional, though it can be waived for a new or renovated dental installation using only a panoramic unit with no cephalometric capability.
In practice, the physical shielding still looks similar to what you'd see anywhere else, even though Hawaii's process for approving it is more hands-on: lead-lined control booth walls and doors for higher-workload rooms (often in the neighborhood of 1–1.6 mm lead equivalent, though your physicist's calculation — not a table lookup — is what actually sets the number), lead glass in viewing windows, and in some lower-workload dental or single-unit rooms, ordinary drywall construction may already provide enough attenuation without any added lead. What makes Hawaii different procedurally is that none of this is left to your physicist's file cabinet — the design has to clear IRHB's review before you're finished building, so get your physicist and architect coordinating from the earliest planning stage, well before permits or construction schedules are locked in.
Questions on shielding or licensing requirements? Direct them to the Hawaii Department of Health, Indoor and Radiological Health Branch at (808) 586-4700.
Hawaii doesn't run its own separate "report of assembly" paperwork the way some states do — instead, HAR §11-45-117 folds federal requirements in directly, stating that diagnostic x-ray systems certified under the federal x-ray equipment performance standard, 21 C.F.R. Part 1020, must stay in compliance with that federal standard on top of Hawaii's own rules. That has two practical consequences new installs often miss:
The federal assembly report still applies. If your system is a certified diagnostic unit, or is assembled from components made by more than one manufacturer, federal law (21 C.F.R. §1020.30) requires whoever assembles it to file FDA Form 2579 (Report of Assembly). "Hawaii doesn't have its own form" doesn't mean no form is required — this one comes from the FDA, not IRHB, and it's easy to assume it doesn't apply if you're only looking at state paperwork.
Performance standards are checked at inspection, not filed in advance. Technical specs like leakage radiation limits (100 milliroentgens at one meter), minimum beam filtration, and position-locking/centering devices functioning correctly aren't submitted as a separate acceptance-testing report — IRHB verifies them during its periodic radiological health inspections instead. It's still worth having your installer or physicist confirm these at commissioning, so a filtration or leakage issue turns up on your own checklist rather than an inspector's.
One signage detail is worth flagging because it surprises people in the opposite direction: Hawaii's published facility guides state that a "Caution, Radiation Area" sign is not required on the door of a room housing an x-ray machine, and such a sign must not be placed on the machine itself. What is required is a warning label on the x-ray control assembly, reading: "Warning: This x-ray unit may be dangerous to patient and operator unless safe exposure factors and operating instructions are observed." This detail comes from IRHB's dental-facility guide specifically, so confirm the same posting rule applies to your facility category before assuming it does.
Hawaii runs Radiation Facility Licenses on a two-year cycle, with a fixed department-wide renewal deadline rather than an anniversary date tied to when you first applied. Based on IRHB's published facility guides, facility licenses come due for renewal by March 31 of even-numbered years, while Radiation Service Licenses renew separately by March 31 of odd-numbered years — confirm your specific facility's cycle with IRHB directly, since the department can set the initial expiration date of a brand-new license to align it with this schedule.
| Facility category | License fee |
|---|---|
| Dental x-ray facility (1–4 units) | $30 |
| Dental x-ray facility (5+ units) | $50 |
| Podiatry x-ray facility | $30 |
| Chiropractic x-ray facility | $50 |
| Veterinary x-ray facility | $30 |
| Medical x-ray facility (1–4 units) | $50 |
| Medical x-ray facility (5–7 units) | $100 |
| Medical x-ray facility (8+ units) | $150 |
| Radiation therapy facility | $100 |
| Industrial radiography (electronic) | $50 |
| Other radiation facility, not otherwise listed | $30 |
Multi-category facilities pay one fee, not several
If your facility falls into more than one category — a hospital running both medical and radiation therapy units, for example — you pay only the single highest applicable fee from the table, not a stack of separate category fees. All fees are non-refundable once submitted, and a $25 fee applies to any dishonored check.
IRHB mails renewal notices ahead of your expiration date, but not receiving one doesn't excuse a late renewal — the license lapses and is declared defunct if it isn't renewed on time. Submit your renewal application and fee on or before the expiration date (a mailed payment postmarked by that date counts as timely), and budget for the same 30-to-60-day processing window as a new application.
Questions on state-specific requirements? Contact the Indoor and Radiological Health Branch directly at (808) 586-4700 or doh.irhb@doh.hawaii.gov.
Licensing the machine doesn't authorize anyone to use it. Hawaii licenses the people who take or supervise x-rays through the Radiologic Technology Board (RTB), under Hawaii Revised Statutes Chapter 466J. Unlike some states, Hawaii doesn't offer a separate limited-scope or "basic operator" credential — the RTB licenses only three categories, and each requires full national certification first:
Applications must be typed or legibly printed, notarized, and accompanied by a recent photograph and verification of your national certification. Applicants must also demonstrate good moral character; anyone with a criminal conviction needs civil rights restored before applying. Initial application fees run $60 (plus $5 for each additional license if you're applying for more than one category). Licenses renew biennially, on a cycle that begins thirty days after your birth month, and require 24 continuing education credits per renewal period.
The exemption list under HRS §466J-6 is narrower than it's often assumed to be, and it isn't the whole picture — some professions are authorized to operate x-ray equipment through their own licensing board's rules entirely outside of Chapter 466J, rather than through an exemption within it. Exempt directly under §466J-6: a licensed medical practitioner in radiology (i.e., a radiologist), a licensed practitioner of nuclear medicine, a licensed physician assistant, a licensed doctor of dentistry, a licensed dental hygienist, a licensed dental technician, students in approved radiography/therapy/nuclear medicine/medicine/podiatry/dentistry/chiropractic programs working under direct supervision, and out-of-state radiologists using telehealth. Practicing without a required license (and without one of these other authorizations) is a misdemeanor, punishable by fines up to $2,000 per offense — with each day of continued violation counted separately.
Three professions worth getting right
A general MD is not automatically exempt. The radiology exemption in §466J-6 only covers physicians practicing in radiology or nuclear medicine — a family-practice, urgent-care, or orthopedic physician who wants to personally operate the machine isn't covered by that exemption, and the office needs a licensed Radiographer on staff (or the physician needs their own RTB license) to take the images.
A licensed, practicing chiropractor is authorized — through a separate rule, not the RTB exemption list. Chapter 466J's exemption list only names chiropractic students under direct supervision, but that's not the operative rule here: under HAR §16-76-21, the Board of Chiropractic Examiners' own rule governing the chiropractic license itself states that a "License To Practice Chiropractic" authorizes the holder "to use all necessary mechanical, hygienic, and sanitary measures incident to the care of the body, including x-ray equipment for diagnostic purpose." That's a direct grant of authority tied to the chiropractic license, running in parallel to Chapter 466J rather than as an exemption within it — no separate RTB license is needed. Staying current matters too: HAR §16-76-39 names "radiographic technique and interpretation involving all phases of roentgenology" as a recognized continuing education topic for license renewal, so a chiropractor's license needs to stay in good standing (CE included) for this authorization to hold.
Veterinarians are authorized the same way, by falling outside Chapter 466J entirely. The RTB's licensing scheme governs human healing arts only and doesn't reference veterinary medicine anywhere in the statute, so veterinarians and their staff can operate x-ray equipment on animals under the facility license alone, with no separate RTB operator license required for that use.
Hawaii requires individual dose monitoring whenever a worker's exposure is likely to exceed 10% of the applicable occupational dose limit:
Where monitoring is required, badges must be processed by a laboratory holding current accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP), worn on the torso between the neck and waist, and paired with a control badge stored away from any radiation source. Your Radiation Safety Officer is responsible for reviewing exposure reports and maintaining records. In practice, IRHB survey data shows that very few lower-workload facilities — a lot of general dental offices, for example — actually end up needing badges once the calculation is run, so don't assume either way without checking your own numbers.
IRHB conducts routine radiological health inspections on a cycle that generally runs every three to five years, depending on facility type and equipment. During an inspection, expect IRHB to check:
If an inspection turns up a deficiency, the corrective action notice must be posted in a visible location for five working days within five working days of receipt, or otherwise kept on file and accessible to employees. To stay in good standing between inspections:
One more thing worth flagging if portable or mobile equipment is part of your plans: Hawaii has additional operational rules specific to that equipment (barrier height, minimum operator distance, and more) that go beyond ordinary facility licensing — see our dedicated post on Hawaii portable x-ray regulations for the details.
Before you start
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Ongoing
Bringing a new x-ray system into your practice?
Maven Imaging helps practices across the country source new and refurbished imaging equipment, arrange financing, and get systems installed and running — so licensing paperwork is one of the few things left on your plate.
Talk to a Maven Imaging SpecialistThis post summarizes publicly available Hawaii Department of Health Indoor and Radiological Health Branch information as of July 2026 for general planning purposes and is not legal advice. Requirements, fees, and processing timelines can change — always confirm current steps and fees directly with IRHB before relying on this guide for a filing.