In the Australian Capital Territory (ACT), the Radiation Safety Section of the Health Protection Service administers the Radiation Protection Act 2006 and the Radiation Protection Regulation 2007.
Radiation licensing requirements for dental practices in the ACT include:
- Individual Radiation Licence(s)
All dental care providers operating X-ray apparatus within the practice shall hold an X-ray Apparatus Licence in accordance with ACT government requirements. - Radiation Source Registration(s) (requires licence(s) to possess)
- Installation Notification
- Radiation Management Plan
General dental X-ray sources include Intra-oral X-ray units, Panoramic X-ray units, Cephalometric X-ray units.
Dentists, dental hygienists, dental therapists and oral health therapists that use general dental X-ray sources must be registered as a dental practitioner with Australian Health Practitioner Regulation Agency (Ahpra).
Dental assistants and dental nurses that use general dental X-ray sources must have training, knowledge and or experience in dental assisting such as a Certificate IV in Dental Assisting – Radiography (HLT43007).
Specialist dental X-ray sources include Dental 3D Volumetric, CBCT X-Ray Units.
Dentists, dental hygienists, dental therapists and oral health therapists that use specialist dental X-ray sources must be registered as a dental practitioner with Ahpra and have training, knowledge and/or experience in radiation safety with respect to dental 3D volumetric X-ray apparatus.
Further information is available at: https://www.act.gov.au/health/businesses/radiation/register-a-radiation-source
Radiation Management Plan
In the ACT, a Radiation Management Plan is one of the requirements of the Radiation Protection legislation. A plan must be submitted with every new radiation source registration application. This plan is the primary document that describes how a radiation source is dealt with, by whom, and the procedures for management of the source and radiation protection at the premises or use location. The plan must be available to anyone who may work with the radiation source. The plan should be reviewed at least annually and updated with any changes in procedures, staff or equipment. If you are renewing your radiation source registration, an updated plan may be required.
You must have a radiation management plan in place for each location.  The plan must detail how compliance will be achieved at your premises in line with the Radiation Protection Act 2006.
Your plan must include:
- a current list of radiation sources at the premises, including the source for which registration is being sought
- proposed dealings with the radiation source
- the proposed location of the radiation source, including how and where it will be stored
- potential hazards associated with the radiation source
- a current list of licenced users for each radiation source at the premises
- security measures to prevent unauthorised dealings or access to the radiation source
- proposed safety measures for dealing with the radiation source, including:
- how the source will be transported or disposed of
- how your practice will deal with radiation incidents and accidents
- the practice’s emergency response
- the name and contact details (including phone number) of the responsible person. The responsible person is defined in the glossary of the RPS C-1 as the possession licence holder, who is solely responsible for radiation safety within their organisation
- name and contact details (including phone number) of the radiation safety officer, who must be:
- someone employed to provide daily advice and supervision services on behalf of the organisation
- suitably qualified
- reasonably available to attend the site as required, having regard to the attendant risk of the source types at the location
- contactable at all times the business is in operation
- an explanation and evidence of how personal radiation monitoring is being achieved within the practice
- any other information prescribed by regulation
Your plan must comply with safety duties under the Radiation Protection Act. It must detail how the radiation source will protect property, the environment and the health and safety of people. This includes providing details about how exposures to both workers and the public will be kept below established dose limits and as low as reasonably achievable.
Dental Radiation Management Plan Templates and additional links are available at:
https://www.act.gov.au/health/businesses/radiation/register-a-radiation-source/radiation-management-plan
The Reference documents required are:
• Australian Radiation Protection and Nuclear Safety Agency. Radiation Protection Series Publication No. 1 Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (RPS1) March 2002
- Australian Radiation Protection and Nuclear Safety Agency. Radiation Protection Series Publication No. 6 National Directory for Radiation Protection Edition (RPS 6) February 2014
- Australian Radiation Protection and Nuclear Safety Agency. Radiation Protection Series Publication No. 10 Code of Practice and Safety Guide Radiation Protection in Dentistry (RPS 10) December 2005
- Australian Radiation Protection and Nuclear Safety Agency. Radiation Protection Series Publication No. 14 Code of Practice Radiation Protection in the Medical Applications of Ionizing Radiation (RPS 14) May 2008
Staff Matters
Roles and Responsibilities: Radiation Protection Series (RPS) No.10 Code of Practice for Radiation Protection in Dentistry (2005) details the role and responsibilities of:
- the Responsible Person
- the clinician operating the dental X-ray apparatus
- the referrer for radiographic examination
- persons supplying, installing and servicing dental x-ray equipment.
Qualifications: The qualifications to operate an X-ray apparatus shall comply with Schedule 6 of RPS 6 and hold:
- dentist registration
- dental hygienist registration
- dental therapist registration
- dental assistant Dental Assistant Certificate IV (Radiography) or equivalent.
Training: All staff shall have radiation safety training included as part of induction training and thereafter at least annually as refresher training.
Regulatory Licensing Requirement: All dental care providers operating X-ray apparatus within the practice shall hold an X-ray Apparatus Licence in accordance with ACT government requirements.
Personal Radiation Monitoring: Appropriate personal radiation monitoring shall be undertaken by staff in accordance with requirements of the X-ray apparatus being used within the practice.
Personal Protective Equipment: Appropriate personal protective equipment shall be worn by all persons involved in the use of radiation sources.
Protection Matters
Work Practices shall comply with:
- ACT standards and codes of practice
- Incorporated documents and instruments
- Australian Radiation Protection and Nuclear Safety Agency. Code of Practice for Radiation Protection in Dentistry (2005)
- Australian Radiation Protection and Nuclear Safety Agency. Safety Guide for Radiation Protection in Dentistry (2005)
- Australian Radiation Protection and Nuclear Safety Agency. Radiation Protection Series Publication No. 14 Code of Practice Radiation Protection in the Medical Applications of Ionizing Radiation (RPS 14) May 2008
Identification Protocol: Staff operating X-ray apparatus shall ensure that the right patient, right site and right procedure protocol is undertaken prior to exposing a patient to diagnostic radiation.
Dose Constraints: The effective dose equivalent limits for radiation exposure are:
• Occupational Exposure: 20 mSv per year
• Occupational exposure (pregnancy) & Public exposure: 1 mSv per year.
Exceeding Effective Dose Equivalents: ACT Health Protective Service shall be notified by the Responsible Person if occupational or public exposure exceeds the equivalent of:
- Occupational Exposure: 5000 direct exposures per year
- Occupational Exposure (Pregnancy): 250 direct exposures per year
- Public Exposure: 250 direct exposures per year.
X-ray Apparatus Specifications: An authorised X-ray apparatus in the practice shall comply with the manufacturers’ specifications or other such ACT jurisdictional requirements.
Construction and Shielding: The minimum room shielding requirement to safeguard occupationally exposed persons and members of public shall be used. All rooms containing an X-ray apparatus shall comply with this requirement:
https://www.act.gov.au/health/businesses/radiation/register-a-radiation-source/shielding-plan
External Radiation Exposure: Optimisation of the shielding and radiographic technique shall be used such that external radiation exposure rates are kept as low as reasonably achievable and, economic and social factors are taken into account. The minimum room shielding requirement to safeguard against external radiation exposure shall be used. All rooms with an X-ray apparatus shall comply with this requirement.
Storage of X-ray Apparatus: Temporary storage of sealed X-ray apparatus or other related radioactive material shall only be stored on-site prior to its disposal or installation.
Transport of X-ray Apparatus: Transport of X-ray apparatus is required to be performed by an authorised agent.
- Australian Radiation Protection and Nuclear Safety Agency. Recommendations for limiting exposure to ionizing radiation (Guidance note [NOHSC:3022(1995)])
- Australian Radiation Protection and Nuclear Safety Agency. National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)]
National Radiological Protection Board, Guidelines on Radiology Standards for Primary Dental Care, Vol 5 No.3 1994 6 Digital radiography exposure doses are significantly less than analogue radiography and thereby the above values are conservative and well within reasonable safety margins.
Disposal of X-ray apparatus: Disposal of X-ray apparatus is required to be performed by an authorised agent.
Reporting Faults: All apparent faults of operation and leaks of X-ray apparatus are to be immediately reported to the Responsible Person or their delegate. An X-ray apparatus deemed faulty by a daily non- technical inspection is not to be used until the equipment has been inspected by an authorised repairer or agent.
Emergency Response: In the event of a radiation emergency incident the building shall be evacuated and the Emergency Services called. The ACT Health Protection Agency is to be notified by the Responsible Person as soon as practicable after the incident is contained.
Emergency Phone 24 hours: (02) 5124Â 9700. The after hours phone number for Radiation Safety is the same as the office number, after hours you will be connected to an on-call officer who will direct your call as required.
Contact Advice
ACT Radiation Council and ACT Health Protection Agency
Phone: (02) 5124 9700, Fax: (02) 5124 5554, Email: hps@act.gov.au
Howard Florey Centenary House, 25 Mulley Street, Holder ACT 2611
Administrative Matters
Quality Assurance:
- annual verification of radiation licence holders
- staff training in radiation safety recorded in individual staff records
- non-technical inspections of X-ray apparatus conducted prior to its first daily operation
- Verification of the credentials of X-ray apparatus repairers and installers.
Implementation of Radiation Management Plan: Radiation safety shall be incorporated into the practice Work Health and Safety program and manual.
Amendments to the Radiation Management Plan are required when there is:
- a change of registration
- an alteration, including upgrade, relocation of the radiation source
- a change of facility in which the radiation source is located, or
- a proposed alteration of the operational practices of X-ray apparatus.
The Radiation Management Plan must be reviewed:
- at least annually
- after a safety incident involving X-ray apparatus
- on amendment of the Radiation Management Plan.
Submission of the Radiation Management Plan is required for:
- a new registration of a radiation source
- a renewal registration of a radiation source
- an amendment made to the Radiation Management Plan.
If you require more information, please do not hesitate to email Advisory Services at advisory@adansw.com.au or call 8436 9944.
