New regulations on ionizing radiation requirements – information for dentists using x-ray equipment
The BDA is advising dentists in England, Scotland and Wales, that new regulations will come into force on 1 January 2018, which will mean 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
We have been advised that GDPs 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.
One change under the new regulation, is in respect to accidental and unintended exposures – there now appears to be an explicit requirement that the employer's procedures must provide that the referrer, practitioner, and patient (or their representative), are informed of the occurrence of any relevant and clinically significant unintended or accidental exposure, as well as the outcome of the analysis of this exposure.
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