Who is permitted to operate dental x-ray equipment in Western Australia?

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X-Ray operator pressing the exposure switch of a dental OPG/CBCT unit.

Disclaimer: This article contains general information which should not be taken as legal advice. Contact the WA Radiological Council or Radiation Health Unit for official information. You may have different requirements imposed on the conditions, restrictions and limitations of your radiation licences, exemptions and registrations.

Introduction

A common question that we get from our clients is “who is legally allowed to operate our dental x-ray machines?”.

In this article, I will explore the answer to this question in the context of the Radiation Safety Act 1975 (WA) [1].

While reading this article, keep in mind that the Radiological Council of Western Australia is authorised to impose ‘conditions, restrictions and limitations’ to your radiation licences or registrations, under Section 36 of the Act; or may grant exemptions to regulations under Section 3 of the Act. Therefore, you may need to comply with specific requirements, and I encourage you to check your radiation licence and registration paperwork for any of these conditions that may apply to you.

Contents

Dentists

Intraoral, OPG and cephalometric equipment

Dentists that are registered with AHPRA in the dental profession do not need to hold a radiation licence to operate intraoral, OPG or cephalometric x-ray systems in WA (Radiation Safety (General) Regulations (WA) regs 3, 34(1)(a)) [2].

Dentistry students that are undergoing training to become a dentist can use intraoral, OPG and cephalometric dental x-ray machines while they are working under the instructions and personal supervision of a qualified dentist or licenced radiographer (reg 38(1d)). The term ‘personal supervision’ means that the supervisor must be available on the premises or field-site to manage radiation safety while the x-ray equipment is being used (reg 2).

Cone beam CT equipment

Dentists are normally required to hold a radiation licence with the WA Radiological Council in order to operate dental cone beam computed tomography (CBCT) systems [3]. This requirement is usually imposed under the standard ‘conditions, restrictions and limitations’ attached to the registrations of dental premises.

According to the Radiological Council’s website, Dentists are required to be registered with AHPRA in the dental profession to be eligible to apply for a CBCT licence. They must also complete one of the CBCT courses that are recognised by the Radiological Council before being eligible to apply for a licence. AHPRA-registered dento-maxillofacial radiologists do not need to attend a CBCT course to apply [3].

Dental ancillary staff

Intraoral, OPG and cephalometric Equipment

Dental ancillary staff include assistants, nurses, hygienists, and therapists. In order to operate intraoral, OPG and cephalometric x-ray equipment, a dental ancillary staff member must hold an approved qualification and must comply with supervision requirements when operating the x-ray equipment (reg 38(1)(c)) [2].

The qualifications that are approved by the Radiological Council are usually stated on the ‘conditions, restrictions and limitations’ attached to the registration of the premises. Recently issued conditions of registration for dental premises have shown the following qualifications as being approved by the Council:

  • Obtainment of an Australian Certificate IV in Dental Assisting (Dental Radiography), or
  • Satisfactory completion of the University of Western Australia’s Dental Radiography Training Course, or
  • Obtainment of an equivalent qualification in dental radiography as determined by the Australian Dental Association.

Students that are enrolled in training to obtain one of the approved dental ancillary qualifications can use intraoral, OPG or cephalometric x-ray units when they work under the instructions and personal supervision of a qualified dentist or licensed radiographer (reg 38(1)(d)).

Qualified dental ancillary staff must also comply with the supervision requirements stated in regulation 38(1)(c). They must only operate x-ray units under the instructions and supervision of an AHPRA-registered dentist or a licensed radiographer. General supervision is required for performing intraoral radiography of the teeth and lateral oblique cephalometry of the jaws. Personal supervision is required for performed panoramic imaging and acquiring other types of cephalometric image projections.

‘General supervision’ means that the supervisor exercises control over radiation safety without necessary being on the premises or field-site, whereas ‘personal supervision’ requires the supervisor to be available on site to control the radiation safety when the x-ray equipment is used (reg 3).

Cone beam CT equipment

Dental ancillary staff are not generally permitted to operate cone-beam CT equipment in WA.

Other personnel

Radiographers

To lawfully operate x-ray equipment, Radiographers (Medical Imaging Technologists), being eligible for ordinary membership of the Australian Institute of Radiography (reg 3), should hold general registration with AHPRA for diagnostic radiography and possess an appropriate radiation licence [3]. They are required to act under the instructions of a dentist or medical practitioner when performing x-rays (reg 38(1)(b)).

Radiography students in training to become a radiographer can use dental x-ray equipment if they work under the instructions and personal supervision of a qualified dentist or licensed radiographer (reg 38(1)(d)).

Service personnel

According to the Radiological Council’s website, service personnel must hold a radiation licence in order to service x-ray equipment. To be eligible for a licence, they normally must attend a radiation safety course that is recognised by the WA Radiological Council, pass an examination in radiation safety, and demonstrate that they have more than 3 months experience in servicing x-ray equipment under the personal supervision of a licensed person [3].

For service personnel that hold an equivalent licence from another state, it may be possible to apply for a WA licence through the Mutual Recognition Act [4]. Application forms and further details can be found on the Radiological Council website.

Vendors

Vendors of x-ray equipment require a license in order to sell or store irradiating apparatus. A licence for sale or storage usually does not allow the holder of the licence to “operate, use, repair or maintain” x-ray machines [3].

Compliance testers

Compliance testers must hold a radiation licence for the purpose of compliance testing and must be endorsed for testing dental x-ray units. The prerequisites to obtain the licence are specified in the Council’s “Compliance Testing Program Requirements” document [5], which is available on their website. A candidate must have first passed a core examination in radiation safety, before passing another written examination in compliance testing. They must then undergo a minimum prescribed amount of practical training under the immediate personal supervision by a licensed compliance tester, being being assessed as competent by an independent Qualified Expert.

Summary

  • Dentists that are registered with AHPRA in the dental profession do not need to hold a radiation licence to operate intraoral, OPG or cephalometric x-ray systems.
  • Dentists must hold a licence in order to operate dental cone beam computed tomography (CBCT) equipment.
  • Dental ancillary staff member must hold an approved qualification and must comply with supervision requirements to operate intraoral, OPG or cephalometric x-ray unit.
  • Dental ancillary staff are not generally permitted to operate cone-beam CT equipment.
  • Radiographers, service personnel, sellers and storers of irradiating apparatus, and compliance testers must hold a relevant license under the appropriate category to deal with x-ray equipment.

References

1. Radiation Safety Act 1975 (Western Australia)

2. Radiation Safety (General) Regulation 1983 (Western Australia)

3. Department of Health, Western Australia, “Licence Prerequisites,” 10 August 2022. [Online]. Available: https://www.radiologicalcouncil.wa.gov.au/Licences/Licence-Prerequisites

4. Mutual Recognition Act 2020 (Western Australia)

5. Government of Western Australia Radiological Council, Radiation Safety Act 1975 – Diagnostic X-Ray Equipment Compliance Testing: Program Requirements, Radiological Council of Western Australia, 2015

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