Texas EPE Requirements: Who, How Often & What's Tested

If you operate an x-ray system in Texas, an Equipment Performance Evaluation — almost always shortened to EPE — is one of the few compliance items that can quietly lapse for years and then cost you on an inspection day. It isn't a service call, it isn't a preventive maintenance visit, and it isn't the same thing as your DSHS registration. It's a defined set of measurements, on a defined clock, documented in a defined way.

Here's what Texas actually requires, machine type by machine type.

What an EPE Is

An EPE is a documented evaluation proving your radiation machine still operates within the tolerances set by the Texas Department of State Health Services (DSHS) Radiation Control Program. A technician takes real measurements — timer accuracy in milliseconds, kVp deviation as a percentage, field misalignment against source-to-image distance — records the numerical readings, marks each test pass or fail, and signs the report.

The requirement lives in Title 25 of the Texas Administrative Code:

• §289.227 — radiation machines in the healing arts (medical, chiropractic, podiatric)
• §289.232 — dental
• §289.233 — veterinary

Registration is what gets your machine legally on the books. The EPE is what proves it still belongs there. Two separate obligations, two separate clocks — and DSHS inspectors check both.

Who Is Allowed to Perform Your EPE

This is where facilities most often get it wrong, because the answer changes depending on what kind of machine you run.

For human-use systems, §289.227(o)(2) is unambiguous: the EPE is performed "by or under the supervision of a licensed medical physicist." A trained service technician can take the measurements, but the physicist approves the testing protocol, determines the entrance exposure measurements, and reviews and signs the final report. Under §289.227(e)(53), that physicist must hold a current Texas license under the Medical Physics Practice Act (Texas Occupations Code, Chapter 602) with a diagnostic specialty.

For veterinary radiographic units, DSHS guidance is equally clear that "EPEs of dental and veterinary equipment does not require involvement of a physicist." What it does require is that whoever performs it holds their own DSHS certificate of registration to provide radiation services. Your local handyman with a dosimeter is not a compliance solution.

One detail that catches facilities off guard: under §289.226(o)(5), the service provider must notify DSHS within 30 days of performing your EPE.

How Often Texas Requires an EPE

There is no single answer — the interval depends on your modality.

Medical, chiropractic, and podiatric (§289.227(o)(1)):

Veterinary (§289.233(j)(5)(N)(i)(IV)): every 5 years after initial installation, for all veterinary radiation machines.

Two cautions. First, the medical intervals run from the date of the prior EPE, not from your registration anniversary or your fiscal year — if you slip, you compound. Second, several service vendors publish a blanket "annual EPE" or put podiatry on the 2-year cycle. That's not what the rule graphic filed with the state says. Work from the intervals above.

The 30-Day Triggers Nobody Budgets For

Independent of the recurring schedule, an EPE is required within 30 days of any of the following:

1. Initial installation of a new machine
2. Reinstallation of a machine — including a move to a new room or a new location
3. Repair of a component affecting radiation output — the rule names the timer, tube, and power supply, but the list is explicit that it is not limited to those

These triggers apply to human-use machines under §289.227(o)(2) and to veterinary machines under §289.233(j)(5)(N)(i). They also mean your service documentation matters: DSHS guidance advises that service notes should "document clearly whether the repair affects the radiation output," because that service ticket is what a physicist uses to determine whether a fresh EPE is owed.

If you buy a refurbished system, relocate a room, or replace a tube, put the 30-day clock on your calendar the same day the work is scheduled.

What Actually Gets Tested

Medical radiographic systems — per §289.227(o)(6), the evaluation covers:

• Timer accuracy — manufacturer's specification, or ±10% of indicated time if no spec is available, tested at 0.5 second
• Exposure reproducibility — coefficient of variation not exceeding 0.05 for manual and AEC systems
• Linearity — mR/mAs across consecutive mA stations, compared as X₁ − X₂ ≤ 0.1(X₁ + X₂)
• kVp accuracy — manufacturer's spec, or ±10% of indicated setting at a minimum of three points across the normal operating range
• Tube stability — physically stable during exposure, with proper free movement where the tube is designed to move
• Collimation — numerical field size indicators, light field vs. x-ray field congruence, automatic and semi-automatic collimator function, and center alignment with the image receptor
• Entrance exposure (air kerma) limits — measured against Table I of §289.227(j) for every exam type the facility actually performs, including chest PA, abdomen KUB, L-S spine, thoracic spine, cervical spine, full spine, skull lateral, and foot DP

Fluoroscopic systems must additionally satisfy §289.227(m)(1)(C) and (m)(3) — x-ray field vs. image receptor alignment within 3.0% of SID and entrance exposure rate limits. CT systems must satisfy §289.227(n)(1)(H) — tomographic plane location within 5 mm and patient support increment within ±1 mm.

Veterinary systems carry a shorter list: timer accuracy, kVp, tube stability, collimation, and radiation output. SID accuracy is folded in through the beam-limiting device requirements, which put the numerical SID indicator and field centering within 2.0% of SID. Notably, entrance exposure limits, reproducibility, and linearity are not required on veterinary EPEs — DSHS's own training guide states that linearity "is not verified on EPEs for Veterinary or Dental systems."

Across all machine types, radiation output measurements must be taken with a dosimetry system traceable to a national standard and calibrated within the preceding 24 months (§289.227(i)(14)). An out-of-calibration meter invalidates the report.

What Your Records Have to Show

Under §289.227(o)(3), an EPE record must include:

• The actual measurements and numerical readings — not a summary or a "passed" stamp
• A pass or fail indication for each individual test
• Review and signature by the licensed medical physicist, including license number

DSHS's example forms — EPERad-1 for radiographic, EPEVet-1 for veterinary, EPEDent-1 for dental — show the expected level of detail and are a useful yardstick for whether a vendor's report will hold up.

Retention is long. Equipment performance evaluations and the records of any resulting corrections must be kept 10 years under the §289.227(s)(1) records table. Dosimetry calibration records and maintenance/repair records are kept 5 years. Records may be maintained electronically, but they must be available at the site — including authorized record sites for mobile services — for agency inspection.

When a Test Fails: the 30/90 Rule

A failed item on an EPE is not automatically a violation. Ignoring it is.

Correction or repair must begin within 30 days of the evaluation, following a plan designated by the registrant, and must be completed no later than 90 days from discovery unless DSHS authorizes otherwise in writing. The same 30/90 structure appears in the veterinary rule at §289.233(j)(5)(M). Keep the repair documentation with the EPE report — inspectors look for the closed loop, not just the finding.

Quick-Reference Compliance Checklist

• ☐  Machine registered with DSHS, biennial fees current
• ☐  EPE performed within 30 days of installation, reinstallation, or output-affecting repair
• ☐  Recurring EPE on the right interval: 2 years radiographic, 4 years podiatric, 14 months fluoro/CT, 5 years veterinary
• ☐  Performed by a licensed medical physicist (human use) or DSHS-registered service provider (veterinary/dental)
• ☐  Report shows numerical readings and a pass/fail per test, signed with license number
• ☐  Dosimetry system calibrated within the last 24 months
• ☐  Any failures corrected — started in 30 days, closed in 90 — with documentation attached
• ☐  EPE records retained 10 years and available on site

Frequently Asked Questions

Is an EPE the same as preventive maintenance? No. PM keeps the equipment running; an EPE is a regulatory measurement and documentation exercise. A PM visit does not satisfy §289.227(o), and an EPE does not replace your service contract.

We just bought a refurbished system. Does it need an EPE? Yes — within 30 days of installation, regardless of whether the unit was evaluated at its previous location.

Do we need an EPE if we only moved the machine to another room? Yes. Reinstallation is its own 30-day trigger.

What about mammography? Mammography carries separate federal MQSA requirements including an annual medical physicist survey, on top of Texas requirements. Don't assume one covers the other.

What happens if we miss an EPE? Missed evaluations and incomplete records are common inspection findings and can lead to enforcement action under the Texas Radiation Control Act (Health and Safety Code Chapter 401). The practical risk is that a lapse is discovered during an inspection, when you have the least ability to fix it quietly.

This post summarizes publicly available Texas DSHS Radiation Control Program information as of August 2026 for general planning purposes and is not legal advice. Rule requirements can change; verify current text at dshs.texas.gov before relying on any interval or tolerance cited here.