Cabinet X-Ray and XRF Machine Registration in California
If your facility just took delivery of a benchtop XRF (x-ray fluorescence) analyzer or a cabinet x-ray unit, the registration clock is already running.
If your facility just took delivery of a benchtop XRF (x-ray fluorescence) analyzer or a cabinet x-ray unit, the registration clock is already running. California gives you 30 days to register the machine with the California Department of Public Health, Radiologic Health Branch (CDPH RHB) before you operate it routinely. Most facilities miss the deadline not because they refuse, but because no one told them it existed.
This page covers what cabinet x-ray and XRF machine registration in California actually requires: who CDPH is, what form you file, what information you need ready, and what comes after the registration is on file. For the broader picture of how registration fits into a written program, see our California radiation safety program guide.
Who CDPH RHB Is and What Registration Means
CDPH RHB is the California state authority that regulates radiation-producing machines. As an Agreement State, California also administers radioactive-material licensing through CDPH RHB’s separate radioactive-materials program, but that is a different regulatory pathway from machine registration. This page covers machine registration only: industrial x-ray units, cabinet radiography, benchtop XRF analyzers, and similar electronic radiation sources.
Registration is how CDPH knows your machine exists. It puts your facility into the inspection cycle, identifies a responsible person at your site, and creates the record that has to be on file when an inspector arrives. A machine in service without a current CDPH registration is the most straightforward deficiency an inspector can write.
Federal rules under 10 CFR Part 20 also apply through California’s Title 17, which incorporates the federal radiation protection standards by reference. Cal/OSHA covers the worker-protection side under 8 CCR §5191. Registration with CDPH is the entry point that ties all of it together.
The 30-Day Rule (Title 17 §30108)
California Code of Regulations Title 17, §30108 requires every facility that possesses a radiation-producing machine to register that machine with CDPH within 30 days of acquisition. The deadline runs from when the machine arrives at your facility, not from when you finish unpacking it or commission it for use.
A few practical notes on how this works in the field:
- It applies to used machines too. A cabinet x-ray unit transferred from another site, or a benchtop XRF bought used, still requires a new registration under the receiving facility’s name and address.
- Each machine gets registered. If you operate multiple units, each is registered. CDPH wants the make, model, and serial of each one.
- Decommissioning is also a notification event. When a machine leaves service or leaves the site, CDPH expects to be told.
The 30-day window is short on purpose. CDPH does not want unregistered machines accumulating across California while paperwork queues up internally at the buyer.
What You Need to Register
CDPH uses an online registration portal (cdph-rhb.powerappsportals.us) backed by the standard registration application, historically referenced as RH 2261. Before you start the application, gather:
Machine details:
manufacturer, model number, serial number, date of acquisition or installation, primary use (e.g., metals analysis, plastics QC, materials R&D)
Facility information:
legal business name, site address, mailing address, primary contact, billing contact
Radiation Safety Officer:
the named individual responsible for the program at your facility, with their title and contact information (see our Radiation Safety Officer duties and California requirements for how this role is formalized with a written delegation of authority)
Use and operator information:
number of operators, hours of operation, type of work performed in the cabinet
Existing program documentation:
if you already have a written Radiation Protection Program, CDPH may request a copy during the review
Registration fees apply and vary by machine count and facility type. We do not quote those here because they change; CDPH’s current fee schedule governs.
How Cabinet and XRF Registration Typically Moves
For a single-machine facility with an enclosed cabinet unit, the registration itself is relatively straightforward once the supporting pieces are in place. The sequence we walk clients through:
Confirm the machine type in writing.
Cabinet, fully enclosed, electronic radiation source (no sealed isotope). This determines that CDPH RHB is the right authority and that the registration pathway applies.
Designate the Radiation Safety Officer.
CDPH expects a named person on the registration. The RSO designation is documented with a written delegation of authority signed by management.
Gather machine and use data.
Manufacturer, model, serial, date of acquisition, operators, primary application.
Submit the registration through the CDPH portal.
The online portal walks through the required fields. Paper submissions are still accepted but slower.
Pay the registration fee
per CDPH’s current schedule.
Retain the registration verification.
CDPH no longer issues Certificates of X-ray Machine Registration (effective June 26, 2024). Verify registration status through CDPH’s online system, retain the facility registration number and portal records, and keep documentation with the written program.
CDPH may follow up with questions during review. If your written Radiation Protection Program is not yet built, that work runs in parallel: the registration says the machine exists, the written Radiation Protection Program says how you are going to operate it safely.
A Note on Scope: What We Register
Most facilities calling us about radiation machine registration have one of three machines:
- A benchtop XRF analyzer used for metals or alloy verification, plastics analysis, or incoming materials inspection
- A cabinet x-ray unit used for QC on small assemblies, electronics, or food packaging
- A similar fully enclosed industrial radiography unit where radiation cannot operate when the cabinet is open
CDMS writes programs and supports registration for those cases. Facilities operating open x-ray machines, x-ray rooms, shielded-room or field radiography, or sealed radioactive sources have a different regulatory pathway and need a health physicist. We do not handle those engagements. Confirm in writing what equipment you have before any registration support is committed.
This is not gatekeeping for its own sake. It is the difference between staying in CDPH RHB’s cabinet radiography lane and pulling in scope (medical, nuclear, radioactive materials, DOT transport) that requires a different specialist.
After You Are Registered
Registration is the first checkpoint, not the finish line. Once your machine is on file, California expects:
- A written Radiation Protection Program on site that reflects your specific machine, operators, and procedures
- The RH 2364 “Notice to Employees” poster posted where operators see it
- Documented operator training, including the machine-specific written and practical exams the program requires
- An annual audit of equipment, procedures, and training records, with results documented
- Records kept and available for the CDPH inspection cycle (inspection frequency is governed by Health and Safety Code §115085 and depends on machine type and use)
A registered machine without these pieces in place is a registered machine waiting to receive a notice from CDPH. We see it regularly: the registration was completed, then nothing else followed, and the inspection two or three years later turned up four deficiencies that could have been closed out in the first month.
How CDMS Helps
When a California facility calls us about a new cabinet x-ray or XRF, we usually do four things together:
Verify the machine is in scope (fully enclosed, electronic, cabinet) and gather the registration data.
Help you complete the CDPH RHB registration on the state portal, with the RSO named and the machine details correct.
Write the Radiation Protection Program tailored to your specific machine and operators.
Deliver radiation awareness training and the machine-specific written and practical exams the program requires.
We come to your facility. We do not ask you to ship documents to us or run the registration yourself. The first walkthrough is what tells us whether the machine, the location, and the operators line up with what CDPH expects to see when they inspect.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
Speak with a CDMS EHS expert
Tell us about your facility and your deadline. You’ll get a clear read on what applies and a scoped plan to handle it.