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Dental Radiography Compliance and CQC: Meeting IRR17 and IR(ME)R Requirements

Writer: Liam
Liam
3 days ago
6 min read

Dental radiography compliance rests on two sets of regulations, IRR17 and IR(ME)R 2017, and CQC looks at how you meet them when it reviews whether your practice is safe. Drawing on my 12+ years as a CQC inspector, I explain what each set of rules requires, what inspectors ask and how to get your radiation file in order.

Dental radiography compliance guide: IRR17, IR(ME)R and CQC requirements for dental practices
Dental radiography compliance: meeting IRR17 and IR(ME)R requirements, and what CQC inspectors ask.
Key takeaways
• The Ionising Radiations Regulations 2017 (IRR17) protect staff and the public. The Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R) protect patients.
• You must register with the Health and Safety Executive (HSE) before you start using dental X-ray equipment. It is an offence to work with X-ray equipment without registration.
• You need a radiation protection adviser (RPA) and a medical physics expert (MPE). CQC confirms the same person may fulfil both roles.
• CQC is the enforcing authority for IR(ME)R in England and also considers radiography under Regulations 12 and 15.
• Since 5 May 2026, new oral health service applications to CQC must include an HSE IRR17 registration certificate and a radiography risk assessment and local rules document.

What is the difference between IRR17 and IR(ME)R?

IRR17 is made under the Health and Safety at Work etc. Act 1974. It protects people exposed to ionising radiation through their work, and members of the public. It does not cover patients having dental X-rays.

IR(ME)R 2017 covers medical exposures, including dental X-rays. CQC explains that it sets out the responsibilities of four duty holders, the employer, referrer, IR(ME)R practitioner and operator. Its duties include justifying each exposure and keeping doses "as low as reasonably practicable".

The Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment (2nd edition, 2020), published by Public Health England and FGDP(UK) and endorsed by the College of General Dentistry, explain how to meet both sets of regulations.

How does CQC regulate dental radiography?

What does the CQC dental mythbuster ask?

Dental mythbuster 3 says CQC considers how you use X-rays when reviewing whether your practice is safe, under Regulation 12 (safe care and treatment) and Regulation 15 (premises and equipment). The issues it lists are:

  • How do you put arrangements for radiation protection into practice?

  • Have you consulted an RPA and MPE?

  • Have you registered with HSE, and do you have a certificate?

  • Have you documented your arrangements, for example in a radiation file?

  • Do you quality-assure or test the performance of your equipment?

  • Is the equipment maintained or serviced by an appropriate person?

  • Does a trained member of staff visually inspect X-ray sets for safety faults?

  • Which staff take X-rays, and are they trained to current professional guidelines?

The mythbuster was updated in May 2025 to cover cone-beam CT (CBCT) and hand-held X-ray equipment.

What is CQC's role under IR(ME)R?

CQC is the enforcing authority for IR(ME)R in England, using powers under the Health and Safety at Work etc. Act 1974. Its specialist IR(ME)R inspectors include dental providers in their diagnostic radiology programme by self-assessment. IR(ME)R inspections do not lead to a rating. If an accidental or unintended exposure is significant, the employer must investigate it and notify the enforcing authority under Regulation 8(4).

What does IRR17 require of a dental practice?

  • HSE registration: register before first use and keep the certificate of registration and summary details. A material change, such as starting radiography in care homes with mobile equipment, means updating your registration.

  • RPA: appointed in writing and consulted on matters such as risk assessment, local rules and contingency plans.

  • Local rules: mandatory for work in a controlled area, drafted after consulting your RPA. The guidance recommends an annual review, a version number and issue date, and a record that staff have read them.

  • Radiation protection supervisor (RPS): appointed in writing to supervise day-to-day compliance.

  • Critical examination: the installer is responsible for this on new equipment, and after relocation or significant changes.

  • Safety checks: operators should check warning lights, signals and controls daily, and results should be formally recorded at least every six months.

  • Over-exposures: report to HSE under Regulation 26 of IRR17, including those caused by equipment faults before clinical use.

What does IR(ME)R require of a dental practice?

Justification and authorisation

Before any exposure, an IR(ME)R practitioner must decide that the benefit outweighs the detriment. They must give appropriate weight to factors including previous radiographs, the objectives of the exposure and the patient's age. The guidance says you do not need to record the reasoning behind justification, but your records should show who authorised each exposure.

Clinical evaluation

A clinical evaluation of the outcome of each exposure must be carried out and recorded by suitably trained operators. It must cover the whole image, including any regions outside the area of interest.

Quality assurance

The guidance recommends:

  • routine equipment tests at intervals not exceeding three years, or annually for hand-held equipment and in certain other cases

  • image quality rating and analysis at least every six months, using a sample of at least 100 images where workload allows

  • digital targets of at least 95% diagnostically acceptable images and no more than 5% not acceptable

  • a check of the whole QA programme at least every three years, with clinical audits covering justification and clinical evaluation

What changed for new dental registrations in 2026?

CQC's supporting documents guidance says that, from 5 May 2026, oral health services must send:

  • their current HSE IRR17 registration certificate

  • a radiography risk assessment and local rules document covering all X-ray equipment, the responsibilities of each duty holder, how you protect patients, staff and the public, and how you report over-exposures to HSE

What practical steps should you take now?

  1. Find your HSE certificate and check the details still match your practice.

  2. Confirm your RPA and MPE in writing, and record who your RPS is.

  3. Review your local rules and get every operator to sign that they have read them.

  4. Check your equipment records, including critical examination reports, routine test dates and servicing.

  5. Record your six-monthly visual safety checks.

  6. Run an image quality audit and act on any results below target.

  7. Audit justification and clinical evaluation in a sample of records.

  8. Update training records for everyone who refers, justifies or takes X-rays.

  9. Organise your radiation file so you can show an inspector everything in one place.

Frequently asked questions

Do dental practices need to register with HSE?

Yes. HSE lists dental X-ray devices as work with radiation generators that needs registration. It is an offence to use X-ray equipment without it.

Can the RPA and MPE be the same person?

Yes. CQC's mythbuster 3 says the same person may fulfil both roles.

How often should dental X-ray equipment be tested?

The guidance recommends routine tests at intervals not exceeding three years. Annual testing is recommended for hand-held equipment and in some other situations, subject to your MPE's advice.

Who enforces IR(ME)R in England?

CQC. HSE enforces IRR17.

How I can help with dental radiography compliance

As a former CQC inspector with 12+ years of experience, I offer compliance support and mock inspections for dental practices. I can review your radiation file, local rules, QA records and audits against CQC expectations, and help you prioritise any gaps.

  • Virtual Compliance Review (£499): a remote review of key policies, audits and compliance evidence, with a prioritised action plan.

  • Full Comprehensive Mock Inspection (£1,799): an on-site assessment with evidence sampling, observations, staff interviews and a detailed improvement plan.

Opening a new practice? See my CQC registration support for dental practices.

Email hello@cqcconsultancy.net to discuss your practice.

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