Dent RPA Frequently Asked Questions

We have provided a list of frequently asked questions divided in various categories.

Click the categories below to view the questions and answers.


    Q: What Regulations apply to the use of dental X-rays in the UK?

The Ionising Radiations Regulations 2017 (IRR2017) aim to keep occupational exposures from ionising radiation to dentists, dental nurses, other staff and members of the public as low as reasonably practicable (ALARP). The Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R2017) aim to minimise patient radiation exposure from medical X-ray procedures.


    Q: How are dental practices be affected by the new Ionising Radiations Regulations 2017 and the Ionising Radiation (Medical Exposure) Regulations 2017?

The practical implications for dental practices using X-rays are fairly small following the implementation of the IRR2017 and IR(ME)R2017 regulations on 6th February 2018. However, dental practices now need to register their use of X-rays with the Health and Safety Executive. This is a simple online process involving a self-declaration and a one-off £25 registration fee. The registration website is at http://

The online declaration involves answering a short series of questions covering areas including risk assessment, local rules, appointment of the RPA, staff doses, staff training and demarcation of controlled areas. Clients who follow Dent RPA's handbooks and other documentation/tools provided should already be compliant in these areas and the registration process should not present any concerns. Please contact us at if you need further advice on the registration process.

The implications of IR(ME)R2017 are minor, although our IR(ME)R procedures and protocols handbooks have been updated to address the new requirements. There is a requirement to inform patients of the doses, benefits and risks from ionising radiation and our existing advice sheet on patient doses (see My Toolbox/Advice Sheets) for details) can be used for this purpose e.g. by having copies available in the waiting rooms or surgeries.

There is more emphasis on adequate training for IR(ME)R practitioners and operators and our clients are encouraged to ensure that the Dent RPA equipment-specific proformas are completed for all operators for each piece of X-ray and ancillary equipment that they use.

Our online radiation protection training will be updated in the light of the new regulations once the regulators have advised on their practical implementation (expected by mid 2019). Dentists and dental X-ray operators are unlikely to require immediate IR(ME)R training under the new IR(ME)R2017 if their current training is still in date.


    Q: Who is responsible for ensuring compliance with the Regulations?

IRR2017 - The Employer has the overall responsibility for compliance with the regulations and this cannot be legally delegated. Normal practice is for a dentist or other senior person to be appointed as Radiation Protection Supervisor (RPS) for the practice with the duty of supervising radiation safety in accordance with the local rules.

IR(ME)R2017 – These regulations require policies on identification of the following duty holders in the context of medical X-ray exposures:

Employer - This person that takes legal responsibility for compliance with IR(ME)R. The Employer must ensure that a framework of procedures for medical exposures is in place.

Referrer – An individual entitled by the Employer to refer a patient for an X-ray. Such persons must provide sufficient clinical information to enable justification of the exposure

Practitioner – A qualified medical practitioner i.e. dentist, who is responsible for providing the clinical justification for each individual exposure. The dentist must be able to demonstrate that all radiographs will provide useful medical information that will benefit the patient and outweigh the risks from the resultant radiation. In most dental practices the Practitioner and Referrer are the same person.

Operator – The person who performs the practical aspects of the exposure. The operator is usually a suitably-trained dentist or a dental nurse.
Please see the IRMER procedures template in the “Handbooks” section (under My Toolbox) of the website for further information.


    Q: How do I ensure that my medical exposures are optimised under IR(ME)R2017?

Adhering to published referral criteria such as “Selection Criteria for Dental Radiography”, (published by the Faculty of General Dental Practice (UK)) will help minimise the number of unnecessary X-rays and aid the justification process. Ensuring that the minimum patient dose is used depends on having suitable exposure charts, adequate processing conditions, a fast film system and a quality assurance programme in place. The equipment survey report from the Dent RPA technician will show how the exposures compare to national Diagnostic Reference Levels and have recommendations for remedial action where necessary.

    Q: Is there a legal requirement to have my X-ray equipment serviced?

Regulation 33 of the Ionising Radiations Regulations 2017 states that an employer that has responsibility for equipment related to medical exposures must have it ‘maintained’ so as to restrict dose as far as is reasonably practicable. Further to this, the Health and Safety Executive's Guidance Note PM77 (third edition) entitled "Equipment used in connection with medical exposure" states in the section on equipment maintenance: "Equipment used in connection with medical exposure should be under some form of maintenance/service contract, often with the manufacturer or installer. Alternatively, arrangements may be made with in-house engineers, technical staff. In this guidance, all references to service engineers and service or maintenance includes such in-house arrangements. In any event, the employer has the legal responsibility for ensuring that equipment is properly maintained .....".

While document PM77 is not strictly legally binding, it can be used by the HSE to pursue a prosecution in a court of law where failure to follow its guidance has led to an incident or injury involving ionising radiation. As such, it is the interpretation of Dent RPA's Radiation Protection Adviser that servicing of X-ray equipment is strongly advised under IRR 2017, particularly for panoral and cone beam CT X-ray equipment where there may be mechanical safety and performance issues resulting from the rotation of the unit. We would advise a minimum frequency of annually and this should include ancillary equipment such as CR plate readers and film processors. If a local decision is taken not to service intra-oral X-ray equipment, the three-year tests by the RPA must be kept up to date and there should be an in-house programme of regular checks of the condition of the collimator, cracks in the X-ray tube housing, stability of the arm and any other issues that could affect patient safety.


    Q: Are "controlled area" warning signs necessary at the entrance to rooms and surgeries where intra-oral and panoramic X-ray sets are used?

In practice, the radiation controlled area for most dental X-ray facilities usually extends to around 1 to 2 metres from the patient. However, it is usual to designate the whole room or surgery as “controlled” because of the difficulties of demarcating the actual controlled area. Defining the whole room makes controlling access very straightforward. Technically, the area is only “controlled” when the equipment is in a state where it is capable of emitting X-rays (i.e. when the power is turned on). General X-ray departments overcome this by having a sign stating “Radiation Controlled Area when red light is on”, or similar. However, this system of work relies on the presence of a warning light that is wired into the X-ray equipment so that it illuminates during the prep and exposure and the benefit of doing this for most dental X-ray installations does not usually meet the expense. Another alternative is to have a reversible sign that can be turned around so that the “Controlled Area” text is not visible when the equipment is off. However, it is the experience of the Dent RPA technical team that such signs often go missing or are not turned around, negating their usefulness. As such, Dent RPA's Radiation Protection Advisers are of the view that the most workable solution is to have permanent controlled area signage. This simply means that access is controlled via the arrangements given in section 1.4 of the local rules.


    Q: Is there a legal requirement to appoint a Radiation Protection Adviser or can I take advice on an ad hoc basis?

The Ionising Radiations Regulations 2017 state "...every radiation employer shall consult such suitable radiation protection advisers as are necessary for the purpose of advising the radiation employer as to the observance of these Regulations..". The second part of this regulation states “....the radiation employer shall appoint that radiation protection adviser in writing and shall include in that appointment the scope of the advice ...”. It is therefore an explicit legal requirement that all users of X-ray equipment must have a current contract in place with a suitable RPA. The appointment of an RPA is also part of the declaration for the Registration process with the HSE. The agreement must also be subject to an adequate service specification that ensures that the RPA provides advice on all areas required by the Regulations. Please see the Dent RPA homepage for details of an appropriate service specification.

    Q: Is it possible to complete IR(ME)R/radiation protection training online?

Yes. It is perfectly acceptable to undertake online radiation protection training in preference to a classroom-based course. Dent RPA offer completely free five-yearly online radiation safety and IR(ME)R training to all our customers to meet their statutory and professional radiation protection training requirements. Our online course comprises five hours of verifiable CPD in radiation protection and a certificate of completion is given.

The online training also includes the Health and Safety Executive’s Core of Competence for RPSs and serves as both initial and five-yearly update training for Radiation Protection Supervisors for dental practices.

Customers are sent activation codes for the online training as soon as a contract to provide Radiation Protection Adviser services has been set up.


    Q: Can a patient take their X-rays away with them?

There is no reason in principle that a patient can't take away their dental X-rays, as the notes resulting from the dentist's review of the X-ray constitute the legal record that your practice is obliged to keep. However, there are dangers of providing images to patients (self diagnosis, etc.), and a practice should only comply with the patient's wishes if they can give you reasonable grounds for their request. If you allow them to take away their film images (where there is likely to be only one copy), you should request that they keep the images safe and bring them to future appointments. You should also put in the patient's notes that they have taken away their X-ray images. Digital images can be taken away on CD (or other digital storage media) without restriction.


    Q: What do the Care Quality Commission look for when they inspect a dental practice?

The CQC inspect dental practices to ensure that they are safe, effective, caring, responsive and well-led. More specifically, they aim to ensure that the practice is compliant with current radiation protection legislation and you should ensure that you have appointed a Radiation Protection Adviser. They would look particularly at compliance with the Ionising Radiations Regulations 2017 and IR(ME)R2017. Dent RPA's services aim to fully facilitate our clients' adherence to UK radiation protection legislation and associated guidance. We provide audit tools to enable our clients to determine their level of compliance and help them take remedial action as necessary.

Full details of the CQC's inspection regime and expectations for dental practices can be found at:


    Q: What policies and procedures do I need in place to comply with the IR(ME)R2017 legislation?

IR(ME)R2017 legally requires you to have a set of Employer's procedures and policies that protect the patient from the potentially harmful effects of ionising radiation. These include policies on identification of referrers, practitioners and operators, availability of previous images, patient identification, radiography of individuls of child-bearing potential, optimisation of radiation dose to patients, reporting of radiological examinations and retention of images. It also requires exposure protocols and a quality assurance programme to be in place. A template of such policies and procedures is available to Dent RPA customers to facilitate the process and this can be downloaded from the “Handbooks” section of My Toolbox.


    Q: When will we get handbooks updated for IRR 2017 and IR(ME)R 2017?

The RPS and IR(MER handbooks have been completely updated to reflect the requirements of the IRR 2017 and IR(ME)R 2017 legislation. These can be accessed by going to My Toolbox/Handbooks and clicking “rebuild handbook” against both the IRMER HANDBOOK Version 2 and RPS HANDBOOK Version 2 headings. The “rebuild handbook” function will ensure that the handbooks on your account will be updated with the current versions. Please note that a number of relevant forms are available for download in Word format in the My Toolbox/Handbooks section. These should be completed as necessary to facilitate compliance with the regulations.

    Q: How to I register my use of X-rays with the Health and Safety Executive?

You need to register the use of X-rays with the HSE online by visiting

The process should be straightforward, but please feel free to contact Dent RPA ( in the event of any difficulties.



    Q: Can I continue taking X-rays when I’m pregnant?

Normally, yes. It is extremely unusual for involvement in dental radiography to require a change in working practice during pregnancy. The Employer is required to carry out a risk assessment to ensure that the dose to the fetus does not exceed 1 mSv during the declared term of pregnancy. In practice this means the mother receiving a whole body dose of 2 mSv, which is almost impossible when the local rules are followed. This applies even for very high workloads and when the operator is using a cone beam CT unit. Bear in mind that pregnant employees should not hold patients during X-ray exposures.

    Q: Do staff working with dental X-rays need personal dose monitoring?

Usually not. Staff working in dental radiology do not routinely need to remain in a radiation controlled area during the exposure and therefore personal dosemeters are not generally required. However, it is the Employer’s duty to ensure that their employees are not at risk of approaching the classification level set out in IRR 2017 (i.e. a whole body dose exceeding 6 mSv per annum). Accordingly, a risk assessment should be carried out which may include provision of dosemeters to staff for a trial period. In practice, such a risk assessment need only be considered for those dental X-ray operators whose weekly workload exceeds 100 intra-oral or 50 panoramic exposures, or a pro-rata combination of each type of examination. Introduction of a new technology such as cone beam CT may warrant the introduction of personal dose monitoring for a trial period, especially if the workload is anticipated to be high.

    Q: What should be the content of the Local Rules for my practice?

Local rules for a dental practice are the safety instructions that should be followed to ensure that staff and the public are sufficiently protected from ionising radiation and are a legal requirement under IRR 2017. They should comprise a description of the controlled area, arrangements to restrict access, conditions under which entry is allowed for members of the public, safe working instructions, dose investigation levels (where personal dose monitors are provided), contingency arrangements for foreseeable radiation incidents/accidents (such as inadvertent entry during the exposure) and the names of the Radiation Protection Supervisor and the Radiation Protection Adviser.

Local Rules for your practice can be generated automatically using the online tool in My Toolbox.


    Q: Is it acceptable for staff to hold patients who are undergoing an X-ray examination?

Yes, although it is generally preferable to ask a friend or relative (“carers and comforters” under IR(ME)R 2017) of the patient to carry out this task if possible. If patients have to be held by a member of staff during radiography, it is not necessary to provide a personal dose monitor, assuming the person holding does so only rarely. However, a record of the person's name should be kept. Pregnant persons should not usually hold patients. Lead coats may not be necessary for the person holding the patient during intra-oral radiography where this happens rarely. Patients should not be held during panoral X-ray examinations (other than during exceptional circumstances where the RPA can advise).

    Q: Can the operator remain within the radiation controlled area during the X-ray exposure?

The radiation controlled area for standard dental X-rays (panoramic or intra-oral) usually extends to a distance of 1.5 metres from the patient and this is stated in the local rules. The purpose of designating a radiation controlled area is to prevent unauthorised persons from entering an area where they may be exposed to a hazard from X-rays. However, under the Ionising Radiations Regulations 1999 this does not include the operator as they are authorised to be present. As such, there is no explicit requirement for the operator to remain outside the controlled area during the exposure if they are suitably protected (with a lead coat, for example). The operator should, of course, remain outside the controlled area wherever practicable. In some situations this is not feasible, for example where handheld intra-oral X-ray units are used. However, there is a requirement under IRR99 to ensure that the doses to the operator remain as low as reasonably practicable. This is achieved through the use of a backscatter shield, which effectively reduces the exposure to the operator to nil.


    Q: Do I need to set a dose investigation level for staff exposures?

Dose investigation levels (DILs) for staff exposures are only applicable where staff wear personal dose monitors and the readings for the period can then be compared to investigation levels found in the local rules. However, where anticipated occupational doses are very low, such as general dental radiography, there is no need for personal monitoring and hence no DIL is required. Personal dose monitoring is only required to demonstrate that classification levels have not been exceeded (i.e. > 6 mSv whole body dose p.a.) and following the good practice guidance set out in the Dent RPA Ltd RPS Handbook and local rules also serves this purpose. For non-classified workers i.e. all dental staff, any DIL that may be set is effectively a dose constraint. The Health and Safety Executive clearly state in the Approved Code of Practice: “Dose constraints are not likely to be appropriate for occupational exposures resulting from the following types of work with ionising radiation: (a) diagnostic radiology, nuclear medicine, most radiotherapy and other medical exposures;….”


    Q: How to we know we are not exceeding the new eye dose limit of 20 mSv?

Operator eye doses in dental radiography have been proven to be extremely low (<< 1 mSv p.a.). As such, it is not necessary to measure eye doses to prove compliance with the new 20 mSv eye dose limit under IRR 2017.


    Q: Do I need to give my patient a lead apron when taking a dental X-ray?

Evidence has shown that a lead apron does not reduce the dose to patients undergoing a dental X-ray exposure (neither intra-oral or panoramic). It should therefore not be offered routinely to patients, even for their peace of mind, as this can perpetuate bad practice. The exception to this rule is for vertex occlusal examinations (or other-rarely used views that directly irradiate the abdomen) of pregnant patients. In this case the pregnant patient should be offered a lead apron, if available.

    Q: How do I set and monitor Diagnostic Reference Levels (DRLs) for dental X-ray examinations?

The DRL is a measure of the radiation dose to the patient which should not be exceeded under normal circumstances for standard patients. Due to the difficulties in measuring actual patient doses in dental radiography, the doses are measured by the technician during the 3-yearly equipment checks and the data presented in the survey report. The reference dose for an intra-oral dental X-ray unit is based on an adult mandibular molar exposure and is currently set at 1.2 mGy (0.7 mGy for a child exposure). The reference level is 81 mGycm2 for an adult panoramic exposure and 265 mGycm2 for an adult CBCT (based on imaging prior to placement of a maxillary molar implant). The equipment survey report from will detail your compliance with these levels and give advice on remedial action where local doses exceed these values.

    Q: Can I take an X-ray on a patient who is known to be pregnant?

Yes. Enquiries about whether a patient is pregnant are only necessary in dental radiography where primary radiation is directed at the abdomen. The risk from other dental X-rays to the fetus is effectively zero. Therefore the question of pregnancy will only become necessary in the case of a vertex occlusal or other rarely used views that directly irradiate the abdomen. Your IRMER file should have a procedure for dealing with potentially pregnant persons and this should reflect the information above.

    Q: Does a thyroid collar reduce the dose to the patient from a panoramic dental X-ray?

A thyroid collar can potentially cut the patient dose from a panoramic dental X-ray. However, they can be difficult to use and frequently cause artefacts where the collar attenuates the X-ray beam. As such, thyroid collars should not be used routinely.

There may be benefits from using thyroid collars for cone beam CT procedures. However, the evidence is still inconclusive and Dent RPA will formally advise in due course.


    Q: What effect does rectangular collimation have on the patient dose from an intra-oral X-ray exposure?

Rectangular collimators can halve the patient dose from intra oral X-ray exposures and should be used where feasible.

    Q: Will I need to change my intra-oral exposure settings if I introduce a digital imaging system?

It is highly likely that your exposure times can be reduced for intra-oral radiography once a digital system has been introduced, although the optimum kV settings are unlikely to change. As a rough guide, the exposure time for a phosphor plate imaging system is likely to be around half that of E-speed film, and a solid state sensor is likely to require around a quarter of the exposure of E-speed film. You are advised to contact Dent RPA ( for advice before you commence using a new digital system. Where we have already completed your equipment surveys, we can usually advise on the optimum settings for a digital system without visiting the practice.


    Q: What training is required for operators of X-ray equipment (intra-oral and 2D panoral)?

Dental Practitioners registered with the General Dental Council must have an undergraduate degree conforming to the undergraduate dental curriculum in dental radiology and imaging as well as the core curriculum in dental radiography and radiology for undergraduate dental students. Refresher training on radiation safety must be integrated into the five-year re-certification cycle for dental Practitioners and Operators.

Dent RPA offer our customers completely free five-yearly online radiation safety training to our customers to meet this requirement. The course comprises five hours of verifiable CPD in radiation protection and a certificate of completion is given.

A nurse operating dental X-ray equipment will usually have completed the Certificate in Dental Radiography.

Equipment-specific training on each X-ray and processing unit used must also have taken place and this must be documented.


    Q: Is there a limit on the number of dental X-rays a single operator can perform?

No limit is placed on the maximum number of exposures. IRR2017 requires occupational exposures to be “as low as reasonably practicable” (ALARP) and in some very rare cases personal dosimetry will be necessary to demonstrate this is being adhered to. However, this is not usually necessary if the workload for each staff member is fewer than 100 intra-oral exposures per week. Below this workload it is considered unlikely that any individual could exceed the 1 mSv annual dose limit for a member of the public. Radiography workload levels should be monitored by the Radiation Protection Supervisor to ensure that the weekly limit is not exceeded.

    Q: What training should be undertaken by a Radiation Protection Supervisor for a dental practice?

Radiation Protection Supervisors (RPSs) should undertake training to cover the relevant parts of the Health and Safety Executive's Core of Competence syllabus for RPSs (see the Resources:Training Guidance section of this website). This details the training requirements under the Ionising Radiations Regulations 2017. Training should be updated every five years.

Dent RPA offer free online radiation protection training to all our customers. This includes the Core of Competence for RPSs and serves as both initial and five-yearly update training. The online course lasts up to five hours and can be completed over several sessions. A certificate of completion is given.


    Q: Is it possible to complete IR(ME)R2017 training online?

Yes. It is perfectly acceptable to undertake online radiation protection training in preference to a classroom-based course. Dent RPA offer completely free five-yearly online radiation safety and IR(ME)R2017 training to all our customers to meet their statutory and professional radiation protection training requirements. Our online course comprises five hours of verifiable CPD in radiation protection and a certificate of completion is given.

The online training also includes the Health and Safety Executive’s Core of Competence for RPSs and serves as both initial and five-yearly update training for Radiation Protection Supervisors for dental practices.

Customers are sent activation codes for the online training as soon as a contract to provide Radiation Protection Adviser services has been set up.


    Q: What training is needed for staff involved with cone beam CT procedures?

Operators: Under the IR(ME)R 2017 regulations, the operator needs to have undertaken “adequate training”. The operator could be dentist, nurse or other person who is suitably trained. There is no requirement for a Certificate in Dental Radiography, per se, although there is often a local agreement that a Certificate in Dental Radiography is required for nurses who take cone beam CT X-rays. A requirement for the Certificate in Dental Radiography is in line with guidance from the NRPB (now PHE) and is the approach endorsed by Dent RPA. The training from the supplier's applications specialist should be sufficient equipment-specific training for a dentist or nurse using the CBCT unit. It may also be possible for equipment-specific training to be obtained via peer-to-peer training e.g. where there is a local "super-user" who can ensure that colleagues are competent in use of the CBCT equipment.

The operator should also attend a theoretical IR(ME)R course where this syllabus is not covered in the Certificate in Dental Radiography.

The operator (usually a nurse or dentist) then needs to be given formal entitlement by the Employer (usually the Principal Dentist) to act as operator for the CBCT unit. The forms in the handbooks section of our website can be used for this purpose.

Referrers: It is usual practice for a CBCT referrer to have undertaken formal training to act in this role (although not a statutory requirement). The Cavendish Academy offer an online course for CBCT referrers (see Referrers who do not interpret imaging need to take Level 1. Other classroom-based classes may also be available.

Referrers who also carry out image interpretation: Formal training should be undertaken by persons who interpret CBCT images. The Cavendish Academy offer such training online (see above for link). This would require completion of Levels 1 and 2. There are also classroom-based courses such as those by Jimmy Makdissi (see for details).



    Q: What quality assurance do I need to carry out in my practice?

Audits should be performed on clinical images to assess their quality. The new guidance from FGDP stipulates that images should be rated as either “Diagnostically Acceptable” or “Diagnostically Not Acceptable” (i.e rejects). For digital imaging the minimum standard is to achieve 95% Diagnostic Acceptable (i.e. 5% or less rejects). For film the standard is 90%/10%.

We are in the process of updating the QA tool on our website for recording the outcome of X-ray image rating. In the meantime, clients could adopt a simple paper-based system for rating their images and checking compliance with the FGDP standards.

Please consult the QA section of for the latest guidance on quality assurance for digital X-ray systems.

All safety features and warning devices such as shielding, collimation, and warning signage must be checked regularly (not exceeding 3 years). Full details are given in the Quality Assurance section of the website under My Toolbox. Dent RPA provide a comprehensive QA package for scheduling, logging and analysing all the QA tests required by current legislation and guidance.

Tests required on cone beam CT systems will depend on the unit and whether a proprietary phantom and other QA tools have been supplied by the manufacturer. Dent RPA and the supplier can advise as necessary.


    Q: What in-house tests should I be doing on my phosphor plate (computed radiography) system?

There is no requirement to carry out any in-house testing of computed radiography (CR) plate reader systems. However, the reporting monitor/review workstation should be checked visually every week using the SMPTE test pattern. The process can be found in the QA section of and there is a log for recording that the check has been completed. If the SMPTE pattern is not available, there should be an equivalent test pattern that can be accessed or users could download the pattern from the internet.

The “Detector Condition” test is stipulated for direct digital systems under national guidance and is not specifically intended for CR. However, users could note any apparent deterioration to the phosphor plates and could use this function in the QA section of to record the data if they want to formalise the checks.

Each individual radiograph should also continue to be rated as excellent, diagnostically acceptable or poor, as with film.


    Q: How often should my cone beam tomography unit be tested?

The imminent new guidance from Public Health England (to be published via the Faculty of General Dental Practice website) will state that the frequency of quality assurance testing of cone beam tomography units by the Radiation Protection Adviser/Medical Physics Expert will reduce to 3-yearly (from annually under the previous guidance). However, this is dependent on a phantom being available to the user to facilitate in-house quality assurance checks (typically weekly to monthly). Dent RPA Ltd will offer 3-yearly testing as the default option for new contracts. However, clients may request more frequent testing where necessary.


    Q: Does a dental clinic using an intra oral X-ray unit need lead in the walls?

Generally, no. However, this will depend on the design, layout and workload of each dental practice. The Dent RPA Radiation Protection Adviser must be consulted to give guidance on the design of the facility and warning signage. For example, additional shielding in the walls may be required if factors such as distance, existing shielding from building materials, occupancy of adjoining rooms and workload mean that persons in adjacent areas may exceed the annual dose constraint to members of the public of 0.3 mSv p.a.

    Q: What warning signage is required for areas where X-rays are used?

This normally depends on the position of the equipment with the room or clinic and the extent of the controlled area. For panoramic X-ray equipment, a two stage warning light should normally be installed at the entrance to the room. This should state “X-rays - Controlled Area” when the unit is energized and “Do not enter” when X-rays are being emitted. Warning lights are not normally required for intra-oral dental equipment as it is unlikely that the door of the surgery will open into the controlled area. However, a warning sign stating "Controlled Area: X-rays" and "No Unauthorised Entry" should normally be affixed to the door to the surgery to indicate that X-rays are in use. The RPA can advise on warning signage on a case-by-case basis and the Dent RPA technician will check and advise on warning signage at the time of the equipment surveys.

    Q: Where can I get further advice and guidance?

You can contact a Dent RPA Radiation Protection Adviser at or via the “Ask the RPA” section of the website for advice on any other matter concerning radiation protection.

    Q: Is it possible to complete IR(ME)R2017 training online?

Yes. It is perfectly acceptable to undertake online radiation protection training in preference to a classroom-based course. Dent RPA offer completely free five-yearly online radiation safety and IR(ME)R2017 training to all our customers to meet their statutory and professional radiation protection training requirements. Our online course comprises five hours of verifiable CPD in radiation protection and a certificate of completion is given.

The online training also includes the Health and Safety Executive’s Core of Competence for RPSs and serves as both initial and five-yearly update training for Radiation Protection Supervisors for dental practices.

Customers are sent activation codes for the online training as soon as a contract to provide Radiation Protection Adviser services has been set up.


    Q: When will we get handbooks updated for IRR 2017 and IR(ME)R 2017?

There are very few relevant changes resulting from the implementation of IRR 2017 and the guidance in the current IRMER and RPS Handbooks is still correct (even though it references the old legislation). Dent RPA's new handbooks (written for IR(ME)R 2017 and IRR 2017 are now available and a bespoke electronic version can be requested by emailing


    Q: What happens if I need to take X-rays from within the room during aerosol-generating procedures?

The current pandemic means that staff may be required to stay in the room during aerosol-generating procedures (AGPs). This will mean that staff are unable to leave the room during an X-ray procedures that are required during the AGP and may therefore be unable to follow the systems of work set out in the local rules. Where this is the case, a risk assessment should be performed. Dent RPA Ltd have provided a proforma risk assessment template for this purpose which can be download here.

Our generic risk assessment for in-room X-rays during AGPs indicates that staff may perform a significant number of intra-oral X-rays in this scenario, provided that they remain at the foot end of the patient and maintain the maximum distance practicable, which should be at least 1.5 metres from the patient's head. Staff may also remain behind the patient's head at a distance exceeding 1.5 metres where standing at the foot end is impractical.

The generic risk assessment indicates that personal dose monitoring should not be required for this scenario, provided that the workload assumptions are not exceeded and the recommended minimum distances can be achieved by all persons in the room during the X-ray.

These temporary arrangements should be documented as an addendum to your existing local rules so that all staff are aware of the systems of work to be followed. A proforma local rules addendum is provided here.

You are advised to contact the RPA (email for further advice if you cannot achieve the distances required by the risk assessment.

Where the exposure switch is outside the room, an arrangement for another person to initiate the exposure may be put in place (subject to suitable training). Good communication is essential in such situations. Staff in the room must communicate that the imaging equipment has been positioned and the patient is ready for the X-ray. Staff initiating the exposure must communicate that the correct exposure factors have been selected and that the exposure is about to commence. They should also communicate to staff in the room when the exposure has terminated.

Practices should consider the practical implications of imaging during AGPs when, for example, the phosphor plate reader is shared between a number of surgeries. Additional plate readers may be required where the door cannot be opened during the AGP and the result of the X-ray is required immediately.


    Q: Should I be concerned if my 3-yearly X-ray equipment testing is overdue during the Covid-19 pandemic?

We are aware that clients may have concerns about compliance and safety where X-ray equipment testing from the RPA goes beyond the 3-yearly due date. You will be aware that Dent RPA Ltd technicians may not be able to visit for the scheduled testing during the current pandemic and may have to cancel routine visits during lockdown periods. However, the IRMER inspectorate at the Care Quality Commission recognise these difficulties and acknowledge that X-ray equipment testing visits may need to be delayed. A formal statement on the CQC website states that a risk-based approach to equipment testing should be taken in conjunction with the Medical Physics Expert/Radiation Protection Adviser. In view of the very low risks presented in dental radiology, we would advise our clients that delays of up to six months in the equipment testing schedule are very unlikely to present a significant radiation risk to staff or patients and would be considered consistent with current CQC guidance. Sites with immediate concerns about equipment safety or performance should contact us for further advice.


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