The Environment Protection Authority (EPA) regulates the use of radiation in dental surgeries in NSW. This information sheet provides an overview of the regulatory requirements which are outlined in the Protection from Harmful Radiation Act 1990 and the Protection from Harmful Radiation Regulation 2025.
Radiation Management Licence (RML)
A Radiation Management Licence (RML) is required for premises in NSW that own, store, sell, give away and operate X-Ray units. The licensee (who may be a person or company) must comply with the conditions to which their licence is subject and the obligations of ’responsible persons‘ as they apply to: EPA Radiation Standard 6
The obligations include, but are not limited to:
- The requirement to have a radiation management plan (from 1 September 2026). Templates can be found on the EPA website. The Advisory Services Radiation Management Plan (RMP) Guide has been established to assist you to complete the RMP template for your practice
- Radiation incident reporting
- Compliance testing by a consulting radiation expert (CREs), see below
- Compliance with ARPANSA’s Code for Radiation Protection in Planned Exposure Situations and Dental Code
- Renewal annually
- A list of individual X-ray units in your practice and their RRM
Certification and Compliance testing
X-ray equipment must undergo certification and compliance testing by an accredited Consulting Radiation Expert (CRE):
- At installation
- Every 5 years
- After tube head replacement
- After relocation even in the same premises.
Radiation Regulated Material (RRM)
Every X-ray unit requires a Radiation Regulated Material (RRM) ID Number that identifies that particular piece of equipment for its lifetime. It is the responsibility of the practice/licensee to list every piece of equipment with a RRM ID Number on the RML.
Signage
Premises that house X-ray equipment must display correct radiation warning signage in the immediate vicinity of imaging/controlled areas. The sign must have the symbol displayed in black , and the lettering “caution radiation “ above the symbol in black on a yellow background.
Radiation User Licence (RUL)
Dental Practitioners
Registered dental practitioners (dentists, oral health therapists, dental therapists and hygienists) do not require a user license to take intraoral radiography, OPGs or Cephalometric radiographs. Dental practitioners require an IA24 licence when taking a CBCT.
Dental Assistants
Dental assistants with a Certificate IV (Dental Radiography) can take intraoral radiography, OPGs or Cephalometric radiographs without needing a Radiation User License. They must have completed an EPA approved course of training, be under supervision, and comply with ARPANSA Dental Code requirements and other obligations. Dental assistants require an IA24 licence when using CBCT apparatus.
Additional Information:
More detailed information can be found on the EPA website:
https://www.epa.nsw.gov.au/your-environment/radiation/managing-radiation-nsw
ARPANSA Code of Practice for Radiation Protection in Dentistry:
https://www.arpansa.gov.au/sites/default/files/legacy/pubs/rps/rps10.pdf
Environmental Protection Authority Radiation Standard 6
https://www.epa.nsw.gov.au/sites/default/files/24p4504-standard-6-part-3-dentistry.pdf
Free ADA NSW Member Webinar: Dental Radiography Compliance: What Your Practice Needs to Know
Mastering Radiation Safety and Compliance in NSW On-Demand Course, free for Members
If you require more information, please do not hesitate to email Advisory Services at advisory@adansw.com.au or call 8436 9944.