Radiation safety compliance
This update outlines compliance concerns raised by the Office of Radiation Safety and provides guidance to help oral health practitioners and dental practices to meet their legal obligations under the Radiation Safety Act 2016 (Act).
1 | Supervision requirements for unauthorised persons taking dental radiographs
- Individuals using an X-ray who are not authorised (i.e. not hold a use licence) must be directly supervised by an authorised person.
- Direct supervision means the authorised person must be physically present and able to intervene during the radiographic procedure (a requirement under s5(1) of the Act).
- Office of Radiation Safety advice indicates an authorised person “elsewhere within the facility” does not satisfy this requirement.
- An authorised person could be a practising oral health practitioner whose scope of practice includes taking radiographs – automatically granting them a use licence under the Radiation Safety Regulations.
To ensure clarity, the Council has updated its Restricted activities policy to align with this definition of direct supervision for the taking of radiographs by unregistered assistants.
The following resource is a useful tool for dental practices to support radiation safety compliance:
Code of Practice for Dental Radiology: ORS C4
2 | Radiation source license requirements
- The Office of Radiation Safety has advised that the Ministry of Health has taken enforcement action against oral health practitioners who have breached the Act by not having a valid radiation source licence.
- This has resulted in several prosecutions.
- Please ensure you are familiar with the information provided by the Office of Radiation Safety and share this with your practice management.
Important notice from the Office of Radiation Safety for all oral health practitioners and dental practices that possess, manage, or control radiation sources
Recent inspection data from the Office of Radiation Safety has revealed that 13% of dental locations were found to be operating without a valid licence or with expired licences during 2024–2025.
These figures may underrepresent the true extent of non-compliance, as the report noted that many practices applied for a licence upon notification of inspection.
Legal requirements
The person responsible for the management and control of each radiation source must at all times hold a source licence issued under section 13 of the Radiation Safety Act 2016 (the Act). This requirement applies to all irradiating apparatus including intraoral, panoramic, handheld, and cone beam computed tomography (CBCT) systems, regardless of whether they are in active use or in storage.
Consequences
If your source licence is expired, you will be required to submit a new application. This process takes longer and involves additional fees compared to timely licence renewal.
A person who possesses, manages or controls an irradiating apparatus without a valid source licence is committing an offence under s63 of the Act, and is liable on conviction:
- in the case of an individual, to a fine not exceeding $100,000
- in the case of a person or an organisation other than an individual, to a fine not exceeding $500,000.
In recent months, the Ministry of Health has taken enforcement action against oral health practitioners who have breached the Act, resulting in several prosecutions.
What you should do
As many oral health practitioners manage and control X-ray units, we would encourage you to:
- check that the radiation sources you use or possess have a valid source licence
- apply for a new source licence before beginning operations
- renew your licence before it expires to avoid non-compliance and the higher renewal fees
- apply for a licence variation if there are changes in ownership, practice location, or if the scope of your licence needs to change (for example, when acquiring a CBCT unit for the first time).
For further details and access to application forms, please visit the Ministry of Health’s radiation safety portal:
Ionising radiation safety – Ministry of Health
Your ongoing commitment to regulatory compliance helps protect patient safety and maintains public trust in the oral health professions.