What's changed in X-ray safety regulations in 19 years?

News Published: 
22 October 2020


As the second edition of the Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment is published, Professor Keith Horner FFGDP(UK)(Hon.), the Faculty’s representative on the Public Health England working party that developed the guidance - and Co-Editor of FGDP's Selection Criteria for Dental Radiography - reflects on the changes in regulations around the safe use of X-ray equipment in dentistry since the guidance was first published 19 years ago...



They say that you know you're getting older when policemen look younger. It is a marker of my advancing years when the Guidance on the use of X-rays in dentistry comes around for revision again. Since I qualified as a dentist in 1981, I have seen three sets of UK Regulations relating to the use of X-rays, each being a response to new European Directives. As a Clinical Academic and Dental Radiologist, one of the less enjoyable aspects of my job was [to try] to understand and memorise the requirements of the Regulations, so that I could teach effectively and give correct advice when asked by colleagues.  Fortunately for all of us, in each case when new Regulations appeared, they were eventually followed by the publication of Guidance written specifically for dental professionals.  

In 2001 the Department of Health published Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment, which aimed to summarise the requirements of the (then new) Regulations to members of the dental team.  As you should all be aware by now, the latest regulations are the Ionising Radiations Regulations 2017 (“IRR17”) and the Ionising Radiation (Medical exposure) Regulations 2017 (“IRMER17”).  In response to these, a second edition of the Guidance Notes, co-published by Public Health England (PHE) and FGDP(UK) and endorsed by the College of General Dentistry has now been published. This document was produced by a working party led by PHE and consisted of regulatory bodies, professional bodies representing dentistry and radiation protection, consultant dental radiologists and general dental practitioners.  I was honoured to represent the FGDP(UK) on the Working Party.  Most of the hard work was done by our PHE colleagues from Dental X-ray Protection Services, who have enormous experience of dental X-ray equipment and the challenges of dental practice through providing Radiation Protection Advisor services.  

Looking back over the years, I couldn’t help but smile when I compared the previous incarnations of Guidance with the new publication. Before 1989, as far as I can remember or find out, there was no specific guidance to assist dental staff in complying with Regulations or to promote the safe use of X-ray equipment. The first Guidance publication in 1989 was a booklet of just 37 pages. The 2001 Guidance Notes had 58 pages, but the 2020 guidance has over 170 pages.  This exponential growth is not a consequence of prolix language or repetition, but reflects how more complicated dental radiology has become since the days when I learned a “film in mouth; put patient’s finger on the film; point the X-ray tube; press the button and hope for the best” technique. My former teachers would not be happy with me for that statement and it is an exaggeration, but things were certainly far simpler in the old days.

So, what’s changed in the last 19 years? Well, first, new Regulations bring new requirements.  An obvious example is that dental practices have to register formally with the Health and Safety Executive (HSE) that they “work with a radiation generator” and pay a small fee, whereas before it was a simple matter of notifying the HSE on one occasion. In addition to appointing a Radiation Protection Adviser to assist in compliance with IRR17, a requirement that existed under the previous regulations, there needs to be a formal appointment of a Medical Physics Expert to advise on IRMER17 requirements (fortunately those jobs can be done by the same people or organisation, so it’s not as complicated as it sounds). As well as revisions of some existing guidance, new guidance was needed for a range of subjects, including legal requirement to assess doses to persons who need to enter controlled areas, working with dental X-ray equipment on another employer’s premises, quality assurance of digital imaging systems, amongst several others. 

As well as these changes, dental radiology itself has changed significantly. Back in 2001, the majority of dental practices were still using film-based radiography; today, digital radiography is predominant and is likely to completely replace analogue systems in the next few years.  The new Guidance places greater emphasis on digital imaging to reflect this change. The introduction of hand-held X-ray equipment for intra-oral radiography and particularly Cone Beam CT have introduced a whole new set of radiation protection challenges.  Although separate publications have been produced by PHE to deal with these new modalities over the years, the new Guidance Notes incorporate them into a comprehensive document.  The Guidance Notes include templates for risk assessments and the wide range of Employer’s Procedures required by the Regulations. An Appendix giving guidance on common image quality faults seen on dental radiographs and dental CBCT scans is a very useful addition.

These are very difficult times for dentistry, and for healthcare generally, and the attention of dental practices is quite understandably focused on getting back to work safely and efficiently in the pandemic. Radiation Protection might be the last thing to worry about. The new Guidance Notes, however, “dot the i's and cross the t's” in terms of using X-rays in dental practice and should help to remove worries about compliance.  

The guidance is free to download from the FGDP(UK) website and hard copies are available to purchase from the online shop. In addition, all paying members of the Faculty in the UK will have received a complimentary printed copy, with members based overseas receiving a copy on request. The new document encapsulates the very best of what can happen when the various individuals and professional backgrounds that make up the Faculty come together, and I encourage you to read it, starting with the preface and then scanning through the contents section. These Guidance Notes will be a valuable resource for dental practices for years to come – well, at least until the next set of Regulations appears! – and I commend them to you.


Guidance Notes for Dental Practitioners on the Safe use of X-ray Equipment 






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