Radiation Resources - Updates Now Available!

With the kind assistance of the Environmental Protection Authority (EPA), ADA SA has recently updated key radiation regulatory resources for dental practices, including:

• Radiation Management Plan (a template for dental practices)
• Radiation licensing requirements

See the new resources here: Radiation Licencing for SA Dental Practice

Did you know?

In South Australia, the use of dental X-ray equipment is regulated under the Radiation Protection and Control Act 2021. This means:

• persons who operate radiation apparatus must hold an appropriate EPA user licence; and
• dental X-ray equipment must be registered with the EPA. 

In addition, business owners who possess radiation apparatus must hold a current Radiation Management Licence (RML).

What types of x-rays can I take?  

Your EPA use licence states clearly the type of dental radiation apparatus you are authorised to operate. Examples may include:

• Intra-oral (plain dental)
• OPG (Orthopantomogram) and Cephalography
• CBCT (Cone Beam Computed Tomography) 

To check your licence conditions, go to: Radiation licences | EPA.

What happens if I don’t comply?

Failure to comply with radiation legislation may result in regulatory action, including:

• expiation notices
• civil or criminal penalties
• radiation protection orders
• suspension or cancellation of licences
• seizure or prohibition of apparatus 

Maximum penalties under the legislation include fines of up to $25,000 depending on the nature and severity of the offence.

It is the responsibility of each practitioner and business owner to ensure all licensing and registration requirements are met before operating or possessing radiation apparatus.

Can I upgrade my licence?

Some practitioners may hold older licence conditions that authorise intra-oral imaging only and do not permit operation of extra-oral apparatus such as OPG or CBCT units.

This may apply to:

• internationally qualified dentists registered with AHPRA; or
• Australian-trained dentists who completed undergraduate training prior to introduction of extended radiography competencies (ie: prior to 2018). 

Eligible practitioners may apply to vary their licence conditions by submitting the EPA variation application form (15496_24b_operate_apparatus_vary_condition.pdf), together with satisfactory evidence of approved training and/or successful completion of an EPA assessment relevant to the imaging modality requested.

TIP: If you wish to update your license to include OPG’s, the ADA and TAFE SA will be running a joint course commencing later in the year. Reserve your place via an expression of interest at: Expression of Interest: Radiation Licensing Courses | South Australia

Important information for business owners:

Any person or business possessing dental X-ray equipment must hold a current Radiation Management Licence (RML).

An RML cannot be granted unless the EPA has assessed and approved a compliant Radiation Management Plan (RMP).

Unless an approved RML has been issued, a business must not possess ionising radiation apparatus.

Radiation Management Plan (RMP)

Dental practices must:

• maintain a current Radiation Management Plan (RMP);
• ensure the RMP accurately reflects the practice’s operations, equipment, procedures and staffing; and 
• notify the EPA by submitting the amended RMP whenever significant changes are made to the RMP. 

Practices should not submit:

• copied RMPs from other businesses. 
• incomplete or partially completed plans; or 
• generic templates without practice-specific information. 

Practices are encouraged to use the ADA SA RMP template as guidance and ensure all information is specific to their individual practice.

Purchasing or installing new dental X-ray equipment requires:

• updating your Radiation Management Plan (RMP) and
• applying to register the apparatus
• once the EPA approves registration provisionally, business owners have 60 days from the date of installation within which:
  - the installed equipment must be compliance tested by an accredited tester;
  - the fully compliant test reports/certificates of compliance are provided to the EPA by the owner

Upon review of the compliance reports, the EPA will convert the provisional registration to full registration.

Important Compliance Reminder

Business owners who install or possess radiation apparatus without an approved Radiation Management Licence (RML) may be in breach of the Radiation Protection and Control Act 2021 and may be subject to enforcement action.

The EPA strongly encourages all practice owners to address regulatory licensing requirements before:

• purchasing a dental practice with existing radiation apparatus; or
• procuring or installing new X-ray equipment for a new practice.

If you should have any questions, queries or concerns, please don’t hesitate to contact the ADA SA Branch at admin@adasa.asn.au

Staff who submit enquiries on behalf of a member dentist are kindly requested to cc the member Dentist into all email correspondence.