In New South Wales, the Environment Protection Authority (EPA) regulates the use of radiation in dental surgeries. This information sheet provides an overview of the requirements for Radiation Licensing and Regulation for Dental Practices in NSW. More detailed information can be found on the EPA website: https://www.epa.nsw.gov.au/your-environment/radiation/managing-radiation-nsw
Radiation Management Licence
The Radiation Management Licence (RML) is the responsibility of the practice and should not be confused with the Radiation User Licence, which is the licence to operate radiographic equipment.
A Radiation Management Licence (RML) is required for premises in NSW that own and operate radiation emitting equipment. The Management Licence is the licence to possess and/or sell radiation apparatus, and is required to be held by a ‘person responsible’ (generally the owner of the equipment).
This licence is renewed annually.
Radiation Regulated Material (RRM) ID Number
A Radiation Regulated Material (RRM) ID Number is given to each specific piece of equipment and stays with that particular piece of equipment for its lifetime.
It is the responsibility of the practice to list/register on the RML every piece of equipment with a RRM ID Number.
Radiation emitting equipment must undergo certification and compliance testing:
- At installation
- Every 5 years
- After tube head replacement
- After relocation
The above can only be done by an accredited Consulting Radiation Expert (CRE)
Radiation User Licence
Registered dental practitioners (dentists, oral health therapists, dental therapists and hygienists) do not require a user license to take intraoral radiography.
A Radiation User License is required by every registered dental practitioner who takes OPGs (Licence IA20) and CBCTs (Licence IA24).
Dental assistants are required to hold a user licence (IA20) to take both intra oral images and OPGs. Dental assistants who wish to apply for a licence must complete an approved course of study (Certificate IV & dental radiography). The names of courses and institutions which have been approved are available on the website at the EPA link above, as are the applicable fees.
OPG
A licence to operate an OPG machine is required for each individual who will be operating the apparatus.
To apply for any licence a dentist, oral health therapist, dental therapist or dental hygienist must hold current registration with the Australian Health Practitioner Regulation Agency (Ahpra).
An OPG falls into the category of “Group One Regulated Material”. There is a registration form and an applicable fee, depending on whether the application is for a new -one or a three-year licence, or for the renewal of an existing licence. https://www.epa.nsw.gov.au/your-environment/radiation/radiation-user-licence/user-licence-introduction/econnect-user-licence-applications
CBCT
There are additional requirements for dental practitioners and dental assistants who wish to apply for an (IA24) licence to operate CBCT equipment.
In order to qualify for IA24, they must meet two prerequisites:
1. Provide evidence of current Ahpra registration (dentist, oral health therapist, dental therapist or dental hygienist), or successful completion of Certificate IV dental assisting, and
2. Provide evidence of successful completion of one of the following:
a) Manufacturer’s or supplier’s cone beam CT applications training course, or
b) In-house CBCT applications training provided by an EPA approved training provider.
Dose limits for young workers
The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) amended the Code for Radiation Protection in Planned Exposure Situations to reduce the radiation exposure limit for occupationally-exposed people who are 16 -18 years of age. The prohibition on any occupational exposure for employees under 16 remains in place.
- The Regulation also updates existing employer responsibilities to ensure young occupationally-exposed persons are not exposed to radiation exceeding the dose limits and are only exposed in the course of training or education and under supervision.
- Schedule 5 of the Regulation sets out the dose limits for exposure to ionising radiation for occupationally-exposed persons, and Clause 26 provides that an employer must ensure that those dose limits must not be exceeded.
- These changes to the Regulation may require employers who employ young occupationally- exposed persons to update radiation safety plans and notify staff.
Clarification of the term ‘employment’ in the Regulation
- A definition of ‘employment’ has been included in the Regulation to clarify that the term includes a person engaged under a contract for service, self-employment and carrying on a business in partnership.
Full document: https://legislation.nsw.gov.au/view/html/inforce/current/sl-2013-0052
Additional Information:
ARPANSA Code of Practice for Radiation Protection in Dentistry: https://www.arpansa.gov.au/sites/default/files/legacy/pubs/rps/rps10.pdf
Environment Protection Authority Radiation Standard 6 – Compliance requirements for ionising radiation apparatus used in diagnostic imaging: Part 3 – dentistry:
EPA information on Radiation User Licences: http://epa.nsw.gov.au/radiation/licensing/index.htm
Disclaimer: This is one of a series of Advisory Services information sheets created by ADA NSW. They are intended as general guides that highlight key pieces of information frequently requested. They do not set out to provide comprehensive information about a topic and they are not legal advice. Please be mindful that information provided in these resources can change after the publication date.
