Avoid the X-rays

You Don't Have To Nuke Your Film!

X-Ray Machines and Film

There is some controversy about how safe it is to x-ray film. That subject is somewhat complex. To learn more about it follow these links. This document will avoid most of the technical issues and concentrate on the practical aspects of the subject. Suffice to say that you should never put your film in checked luggage as security must x-ray all checked baggage. Whether all checked baggage is scanned or not is another topic; please don't play Russian roulette with your film. The silver in the film and the metal package that holds it looks suspicious on a X-ray screener's display. Checked baggage scanners give a larger dose of radiation than carry-on baggage scanners. Your checked bags could be hit with up to 300mR of X-rays by the new CTX series luggage scanners. This much radiation will ruin any and all film. Avoiding all the physics, you should always put your film in your carry-on luggage or this might happen (and that is ISO200!). If you are unlucky enough to be selected for a full security check, the security personnel may put your carry-on luggage through a high power scanner. Even with normal carry-on scanners, you should avoid multiple X-rays. Radiation is cumulative in its effect, just like visible light on film. Should you buy those lead bags to protect your film? Lead lined bags are certain to raise suspicions and if you put it in your checked luggage, the screeners are certain to activate the high power beam on a CTX scanner. Supposedly Sima has a 0.5mm lead bag that will protect ISO800 from just one dose from a CTX-5000. What happens when it gets scanned again? What happens when the screeners open up your checked bag to empty out the lead bag that was a suspicious black blob on their display and then run your film through again without the protective bag? Who wants some unknown screener going through your carefully packed luggage without you there to watch? Why bother with lead when there is a better solution that costs no money and lets you avoid putting your film in X-ray machines at all. How does one avoid having our film exposed to X-rays? Security screeners and regulations in the United States have become more stringent and less accommodating in the aftermath of 9-11. However, this doesn't mean you have watch helplessly as your precious film is exposed to fogging ionizing radiation in the X-ray security machines. The law is on the side of the photographer. Just because a few security screeners don't remember the rules or have been told to overlook them, doesn't mean you, the traveling photographer, should have your film cooked.

The Federal Government and Its Regulations

The Aviation and Transportation Security Act of 2001 (ATSA Public Law 107-71) federalized all airport security screeners and created the Transportation Security Administration (TSA), a new entity created under the Department of Transportation (DOT), just like the Federal Aviation Administration (FAA). Airport security screeners work for the TSA. They are all subject to the Code of Federal Regulations (CFR). The United States Government Printing Office (GPO) keeps an online, up-to-date, searchable, browsable, catalog of CFRs for your convenience. All security screeners in the USA are subject to FAA regulations and the Code of Federal Regulations even if they have not been nationalized yet. This means that anywhere in the United States, its territories, possessions, or commonwealths (Puerto Rico!). If you are going outside the jurisdiction of the United States, you might want to take a couple of those lead bags and double or triple layer them inside each other. Before the TSA was created, the most significant security regulations that concerned flying photographers were listed in Federal Aviation Regulations (FAR) 107 and 108 (parts of title 14 CFR); they are now defunct and have been moved to several Transportation Security Regulation (TSR), that is, Title 49 CFR parts 1540, 1542, and 1544. The new federal regulations are virtually identical to the previous regulations when it comes to film and photographic equipment.

What the Regulations Say

Federal regulations guarantee the right of travelers to have their film and photographic equipment manually checked instead of having it shoved in the X-ray machine. This right means that the screeners may only inspect the film manually, visually, with a magnetometer, with a chemical residue detector, or by requiring you to demonstrate that photographic equipment works. We are mostly interested in Title 49, Subtitle B, Volume 7, Chapter XII, Subchapter C, Part 1544, Subpart C of the Code of Federal Regulations, that is 49CFR1544.2xx

For carry-on luggage:
Section 211 Use of X-ray systems, Paragraph (e) Subparagraph (4):
49CFR1544.211(e)(4) states that "If requested by individuals, their photographic equipment and film packages must be inspected without exposure to an X-ray system."

For checked baggage and specially screened carry-on bags:
Section 213 Use of explosives detection systems, Paragraph (b) Subparagraph (1):
49CFR1544.213(b)(1) states that "At locations at which an aircraft operator or TSA uses an explosives detection system that uses X-ray technology to inspect checked baggage the aircraft operator must ensure that a sign is posted in a conspicuous place where the aircraft operator accepts checked baggage. The sign must notify individuals that such items are being inspected by an explosives detection system and advise them to remove all X-ray, scientific, and high-speed film from checked baggage before inspection. This sign must also advise individuals that they may request that an inspection be made of their photographic equipment and film packages without exposure to an explosives detection system."

What to Expect at the Airport

Some screeners may ask you to put your film or gear into the X-ray machine. They will tell you that, "everything must be x-rayed and everything means everything." As you now know, everything does not have to be x-rayed. If you want to avoid X-rays with the minimal amount of trouble, remember that being polite, courteous, and non-confrontational while still being firm and persistent is the best method. You can catch more flies with honey than with vinegar. "I am a photographer, please hand check my film and camera" works better than "hey, #$!@$, don't $#!@ nuke my #$%@ film, you %##$!" These screeners can pull you out of line for a long "full check" if you anger them, so be nice. Remember their job is not fun and their pay is relatively low. They are just trying to do their job, which is to protect. (Incidentally, if you are pulled off to a "special" room, they may try to scan your carry-on bags in a checked luggage scanner; do not let them put the film through this scanner no matter what!) The screener may insist that the carry-on X-ray machines are not dangerous to films slower than 1000ISO. You can then politely remind them that the regulations they operate under require the option of hand inspection regardless of film speed and also includes camera gear. It might be a good idea to have a few rolls of Kodak TMZ T-Max 3200 to carry around with you so you can say, "look, I have high speed film in my bag!" You can also try marking your film "ISO6400 Push, DO NOT X-RAY" If the screener still demands that the film or equipment be x-rayed, it may be time to quote regulations like a lawyer, but be polite! If you have a lead lined bag, remind them that they will have to hand check anyway because their scanner will see a black blob. If they will not budge, demand to see their supervisor. Remember, you are in the right and they must comply with the very federal regulations that give them the authority to x-ray some things in the first place! Do not be intimidated by them. They get that way because they are impatient and want to keep the line moving. Of course, if you want do want to be annoying for some reason, you can point out that they don't have all the signs back at the baggage checking counter that are required by 49CFR1544.213(b) specifically the one pertaining to optional manual inspection of film. It is a very good idea to print out and carry a copy of at least section 211 to show the more stubborn screeners or supervisors incase they do not remember the rules. You can show the regulations to the friendly National Guardsmen too if you like! If the screener and supervisor continue to refuse to comply and try to tell you that regulations have changed (which you can disprove by the date on the printed out regulations) or flat out ignore the regulations you quote, write down their names. If you have a cell phone, call the FAA right then and there! You know the regulations now, so dial the FAA 24/7 hotline at 1-800-255-1111 on your cell phone and report the specific rule violation to the FAA employee and let the FAA talk to the offending screener. Remember, these rules hardly ever change and they can only be changed by the government, not by the local airport security personnel.

Some Tips for Hand Inspections

Hand checks of film take longer than baking it in the X-ray machine, so budget your time and arrive early. It is advisable to either travel with factory sealed boxes of film which they probably won't ask to open to check the canisters, or to have clear plastic canisters in a clear Ziploc bag to make the search easier and quicker. Fuji packages their film in the clear canisters. Kodak packages some of their professional film in clear canisters too. If you don't shoot Fuji or professional Kodak, you can probably ask your local lab for extra empty canisters. It is worth it to have the clear canisters since the poor screeners won't have to open every single canister to make sure its full of film and not something sinister. You will probably be asked to demonstrate your camera works, so don't travel with camera loaded with film unless you don't mind losing a frame or two at each checkpoint. Shoot with your lens cap on because as of April 26, 2002, it is illegal to photograph (or video) security checkpoints in airports (audio is still legal!). It's best to carry your camera unloaded so you can put it through the X-ray machine so that you are only asking the screeners to hand check your film. If you have several loaded film backs or opened boxes of sheet film, you may be out of luck as there is no way to inspect it for "weapons" without an X-ray machine. The screeners may be content to use a chemical explosive residue detector, which uses a wipe and "chemical sniffer" to detect nitrates (it will pick up fertilizer!) as an alternative to x-raying the film (assuming they have one). However, they will probably still demand to x-ray it. Remember, 120/220 and sheet film won't set off the walk-through magnetometer if you remove the foil. So carry it through the metal detector on your body and hope the screeners don't see the 5x7 boxy bulge in your clothing. Opened boxes of sheet film might warrant one of those lead bags if you don't think they can open the box and handle the plastic bag with your film in it (which they ought to be able to do). Sima's 0.5mm SPX-20 series seems to be the best and wouldn't require layering unless you are putting it through a high power scanner. You can always mail your sheet film ahead of you if you think you are going to have problems. Developing your film during your trip is a fine solution too. X-rays will not damage developed film.

Links to Regulatory Documents

Here is the GPO link to browse Part 1544 or you can print out 211 and 213 individually from the GPO eCFR database. This is the entirety of Part 1544 on one page from the GPO. You can print pages 1 and 11-13 (sections 211 and 213), 1 and 8-31 (Subpart C, i.e. 1544.2xx), or you could print all 39 pages of Part 1544. Page 1 is useful and authoritative looking. All GPO eCFR pages state that they are current as of a certain date. Note: the GPO site is sometimes slow.

If you want to look like a lawyer, you can print out all 119 pages of the relevant Civil Aviation Security Rules (html) from the FAA or print the same thing from a 198 page PDF (with messy handwriting) or Word document (without handwriting) from the DOT (docket number TSA-2002-11602-2). These long documents have several parts of title 14 Aerospace regulations pertaining to the FAA and of title 49 Transportation regulations pertaining to the TSA and state the date at which the regulations became effective. If you carry the large documents, you should probably dog-ear and highlight to make things faster.

Links

You can see what the good people at Kodak have to say: old information, some information with examples of X-ray damage to film (ignore the part about FAR 108 as it is defunct), and new information from Kodak.
Security experiences at various airports (mostly European)
Here is information on some studies on the effects of low power X-ray machines on film. They seem to suggest that it is not dangerous, but I say better safe than sorry especially if your film will be x-rayed more than once and especially with high speed film. The study seems to be subjective by looking at prints (corrected by the printer no doubt) instead of direct examination of negatives with densitometry.
British BAA news release on a study about X-ray effects on film. Same caveat as above.
f-stop.org Film Safety for Traveling - A photographer's rights advocacy group composed of field and industry professionals. Site is out of date.
USPS mail irradiation effects on slides! YIKES!

Want to Sound Like a Lawyer?

"Title 49 Transportation, Subtitle B: Other Regulations Relating to Transportation, Volume 7, Chapter XII Transportation Security Administration, Department of Transportation, Subchapter C: Civil Aviation Security, Part 1544 Aircraft Operator Security: Air Carriers and Commercial Operators, Subpart C Operations, Section 213 Use of explosives detection systems, Paragraph (b) Subparagraph (1) of the Code of Federal Regulations states that, 'At locations at which an aircraft operator or TSA uses an explosives detection system that uses X-ray technology to inspect checked baggage the aircraft operator must ensure that a sign is posted in a conspicuous place where the aircraft operator accepts checked baggage. The sign must notify individuals that such items are being inspected by an explosives detection system and advise them to remove all X-ray, scientific, and high-speed film from checked baggage before inspection. This sign must also advise individuals that they may request that an inspection be made of their photographic equipment and film packages without exposure to an explosives detection system.'"

"Title 49, Subtitle B, Volume 7, Chapter XII, Subchapter C, Part 1544, Subpart C, Section 211, paragraph (e), subparagraph (4) of the Code of Federal Regulations states that, 'If requested by individuals, their photographic equipment and film packages must be inspected without exposure to an X-ray system.'"

I'm NOT a Lawyer

I'm not a lawyer so don't come after me if I am wrong, but please let me know. I study nuclear engineering and I love photography. Remember this information only applies to travelers in the United States and its territories. If you are going abroad, please consider a lead lined bag to protect your film. I hope everyone finds this information helpful! Please email me with questions, corrections, and comments.

Don't Make Me Get a Lawyer

Aaron Parmet parmet@umr.edu

This document took some time to compile. I put it together to help traveling photographers because I was unable to find a site quite like it on the web. All copies, electronic, printed, or otherwise, must credit Aaron Parmet. If you would like to have a copy that is freely accessible to the anonymous public on your webpage, please let me know. If you would like to freely distribute this document in print, please let me know.

Last updated: July 16, 2002

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