New regulations on ionising radiation requirements – information for dentists using x-ray equipment
16 January 2018
The BDA is advising dentists in England, Scotland and Wales, that new regulations came into force on 1 January 2018, which means dentists using x-ray generators must register with the Health and Safety Executive.
IRR17 will replace IRR99 and we can advise that most of the regulations remain unchanged.
However, IRR17 introduces a three-point risk-based system of regulatory control – "notification" (for low level risk activities), "registration" (for the operation of radiation generators) and "consent" (for the highest risks).
General dental practitioners use x-ray generators, so they will be required to apply in the
"register” category (Level 2).
The regulations in Northern Ireland are currently under consultation and we will update members on this, when any changes are announced.
What you need to do
have been advised that the legal person (who is responsible for enforcing the
H&S at Work Act in the practice) will need to register with the Health and Safety Executive (HSE) during January 2018 and apply before 5 February 2018.
We understand there will be an administration charge of £25 to register.
You will need to apply even if you have previously notified HSE that you work with ionising radiation.
We have been assured that the online registration system will be a series of yes/no questions, and we understand this will be similar to the existing process.
We have been told to expect more detailed guidance notes for medicine and dentistry in May 2018.
The current legal requirement
The current legal requirement under IRR99 is for dental practices to appoint a RPA and this requirement remains the same under the IRR17, and that is the appointed person to go to for advice on how a practice updates their radiation protection file.
We understand that:
- For general dental practices, it is registration (rather than notify or consent), unless it refers to a new premises and the HSE has not notified previously.
- The fee is a one-off £25 payment.
- The person responsible for the provision of dentistry as the practice has to register – it does not involve associates having to register, as they are deemed to be "employed" for these purposes
If the practice is part of a wider organisation, the overall owning body will be the one responsible for registering.
- If the entity registering has more than one practice, it will still be £25 only – it is not a "per practice" fee.
- Entities with more than one site will need to state how many sites are involved and the number of employees (including include self-employed dentists and all other staff).
- If you have a number of practices, you should tick the box that gives the spread of the number of your practices; the HSE only require one registration (the exact number of sites is not a major concern and one address will suffice for their records/contact needs).
- If you operate as two separate entities (eg as a limited company and a sole trader) and you share one set of radiation equipment, the HSE would require two registrations, as the fact that they share equipment would be irrelevant.
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