Pay attention, dentists!
UK regulators have recently expressed concern about poor awareness and compliance with radiation protection legislation in dental practices and in some cases this has led to prosecution. All dentists should therefore be aware of the main UK laws and how they should be implemented in practice.
The principal regulations are the Ionising Radiations Regulations 1999 (known as IRR99) and the Ionising Radiation (Medical Exposure) Regulations 2000 (known as IR(ME)R). The key requirements of IRR99 for a dental practice include carrying out radiation risk assessments, appointment of a suitable Radiation Protection Adviser (RPA), designation of radiation controlled areas and ensuring that local rules for safe working practice are in place. The Health and Safety Executive’s Radiation Team is responsible for inspecting compliance with IRR99 and their view following a series of recent inspections of dental practices is that some have paid no attention to its most basic requirements.
As a result these practices have subjected themselves, their staff and members of the public to unnecessary risk and as a result a number of enforcement notices have been issued. The key failings identified by the HSE include lack of appointment of an RPA, poor X-ray equipment maintenance/quality assurance records and lack of adequate risk assessments.
Quality assurance (QA) testing of dental X-ray equipment is required at least every three years under IRR99 and this is usually undertaken by the RPA. More frequent in-house equipment testing is also required by the user under the same legislation. Some RPAs will supply a technician to carry out the three-yearly tests whilst others provide a postal pack for the user to carry out the tests themselves.
Both methods are valid under the law although a personal visit from a technician will usually include a review of the radiation environment and protection arrangements for the practice and can be invaluable when changes to the practice layout or movement of X-ray equipment are planned. The RPA should help with provision of local rules, advice on the radiation protection of staff and patients and radiation risk assessments. Some will also provide support for the in-house QA testing by providing handbooks or software for recording and analysing the test results.
The Ionising Radiation (Medical Exposure) Regulations 2000 are overseen by the Care Quality Commission (CQC) who have recently declared an increased programme of proactive inspections for 2013/4, many of which will be unannounced. The IR(ME)R regulations require a dental practice to have a set of procedures and protocols for medical exposures to protect the patient from the potentially harmful effects of X-rays and ensure that their radiation exposure is minimised.
Written procedures are legally required to cover potential patient pregnancy, optimisation of exposures, patient identification, training requirements for operators and a range of other areas which may influence the safety of the patient. Written referral criteria detailing the clinical indications for dental X-rays are also required under IR(ME)R and interested parties are referred to the text of Schedule 1 of the legislation for full details.
Some Radiation Protection Advisers will provide their customers with an IR(ME)R2000 handbook that covers all the necessary areas and this will help to prove to the CQC inspectors that the requirements of the legislation are being met. The RPA may also provide you with self-audit tools to assess your level of legal compliance and give advice on remedial action that may be needed.
Notification to the HSE of the use of X-rays and registration with the CQC are required under the law. The process for notification and registration to both regulators can be found on their respective websites.
The General Dental Council currently require that its members involved with dental radiography undergo five hours of verifiable continuing professional development (CPD) training in radiation protection in each five-year period. This is to ensure that all X-ray operators are aware of their statutory obligations under IRR99 and IR(ME)R and to help maintain staff and patient safety. A number of providers now offer suitable courses online which can save the time and expense of attending classroom-based training. A certificate is normally awarded as proof of completion for the online courses
All dental practices who use X-rays are urged to take note of the basic requirements of current radiation protection legislation and ensure they have taken reasonably steps to comply. The regulators reiterate that their inspectors have statutory powers which allow them to stop work with X-rays and can lead to legal action. You should consult your Radiation Protection Adviser for further advice and the steps you need to take to ensure that you are fully compliant. Suitable suppliers can be found by searching online for “Dental Radiation Protection Adviser”.