Requirements Within the Practice
The person who is legally responsible for implementing both IRR17 (defined as an ‘employer who works with ionising radiation’) and IR(ME)R (defined as the ‘employer’) [1,2].
The responsibilities of the Employer include:
- appointing and entitling personnel and defining their scope of practice;
- ensuring all X-Ray Equipmentis maintained and tested in accordance with legislation;
- undertaking a radiation risk assessment (see Controlling Exposure and Dose);
- providing referral criteria for radiographic examinations;
- providing Local Rulesfor employees to follow;
- providing Written Procedures and Protocolsunder which IR(ME)R Practitioners and Operators work (see below for details of IR(ME)R Practitioners and Operators);
- staff Training;
- investigating and reporting incidents, in accordance with legislation (see Incidents and Accidents);
- retaining records for appropriate timescales (see the ‘Guidance Notes for Dental Practitioners on the Safe Use of X- ray Equipment’ for recommended retention periods );
- establishing and ensuring that quality assurance programmes are followed.
Radiation Protection Supervisor (RPS)
A person (or persons) appointed by the Employer to help ensure compliance with IRR17 and, in particular, oversee implementation of the practice’s Local Rules. This can be a dentist or a dental care professional (DCP) who has had the appropriate training. According to the HSE Code of Practice for IRR17 , the RPS should know and understand the Local Rules and the requirements of IRR17, have sufficient authority to supervise those carrying out the radiation work, understand the precautions required to restrict exposure and know what to do in an emergency. More than one RPS may be appointed, with the number required sufficient to ensure that the radiation work is adequately supervised. Evidence of relevant training should be available. The appointment of an RPS, including details of their role, should be confirmed in writing (see RPS Appointment Letter Dec 2019 template).
A registered healthcare professional who is entitled by the Employer to refer patients to an IR(ME)R Practitioner for a radiographic examination, following the referral criteria provided by the Employer. On referring a patient, the Referrer must provide enough information to the IR(ME)R Practitioner to correctly identify the patient and for the radiograph to be justified. A history and clinical examination of the patient is required before requesting radiographs. The referrer is usually a dentist but could also be a dental hygienist or dental therapist.
A registered healthcare professional who is entitled by the Employer to justify and authorise the radiograph that has been requested. The role of Practitioner is usually carried out by a dentist although it may be carried out by a dental hygienist or dental therapist, if they are suitably qualified and trained. The Practitioner must justify that the benefits of the exposure outweigh the harm to the patient.
A person who is entitled by the Employer to carry out practical aspects of the procedure, including patient identification, positioning, exposing, processing images, labelling and filing of x-ray film or digital radiographs, ensuring quality control and clinical evaluation of the images. These procedures can be performed by one Operator or by several different Operators. The Employer must define the range of responsibilities (the scope of entitlement) of each Operator.
Under IR(ME)R, duty holders (Referrers, Practitioners and Operators) must be formally entitled by the Employer, or by the person to whom the task of entitlement has been delegated. Each duty holder must be assessed against the registration, qualifications, training and experience required for the tasks that will be carried out in their role, and these competencies will define their scope of practice. An example Employer’s Procedure for Entitlement of Duty Holders (EP1) can be downloaded via Written Procedures and Protocols.This example procedure includes a template for recording duty holders’ competencies.
In dental practice, the same individual will often act as Referrer, Practitioner, and Operator. The Regulations require Practitioners and Operators to be adequately trained and that the Employer keeps up-to-date training records and has these available for inspection (see Training).
State clearly in writing the identity of the Employer.
Appoint a Radiation Protection Supervisor(s) for your practice and record their name(s) in the Local Rules.
Entitle practice personnel to act as Referrers, Practitioners and Operators, ensuring the criteria for each position is met.
Keep records of named individuals, their appointments, entitlements and the scope of their duties in the Radiation Protection File(see Radiation Protection File Overview Sept 2022 template;also example Employer’s Procedure EP1 – Entitlement of Duty Holders Procedure which can be downloaded via Written Procedures and Protocols).
The ‘Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment’ provide more information about IR(ME)R duty holders, including for those involved in dental CBCT imaging .
Sources of Information
- The Ionising Radiations Regulations 2017
- The Ionising Radiation (Medical Exposure) Regulations 2017
- Guidance Notes for Dental Practitioners on the Safe Use of X-Ray Equipment(2nd edition) (2020) Faculty of General Dental Practice (UK)
- Working with Ionising Radiation. Ionising Radiations Regulations 2017. Approved Code of Practice and Guidance(2018) Health and Safety Executive