Radiation Protection in Dental Practices: What CQC Expects Under IR(ME)R and IRR17
Radiation protection in dental practices is about far more than having an HSE certificate in a folder. In my 12 years as a CQC inspector, the practices that struggled were rarely the ones without paperwork. They were the ones where the paperwork said one thing and the surgery floor showed another. Here I focus on the day-to-day side: how your team works around X-ray equipment, and what I would expect them to tell me.
If you want the foundations first (HSE registration, appointing your Radiation Protection Adviser and Medical Physics Expert, the critical examination and IR(ME)R justification), read my earlier post on dental radiography compliance under IRR17 and IR(ME)R. This guide builds on it.
Two sets of regulations, one inspection
Dental X-rays are covered by two sets of law. The Ionising Radiations Regulations 2017 (IRR17) protect staff and the public, and are enforced by the HSE. The Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R) protect patients. CQC enforces IR(ME)R in England, in both the independent sector and the NHS, as its IR(ME)R guidance page explains.
CQC's own Dental mythbuster 3 on dental radiography links radiography to Regulation 12 (safe care and treatment) and Regulation 15 (premises and equipment). It was updated in June 2025 to cover cone beam CT and hand-held X-ray units. So whatever equipment you use, inspectors will look at both strands together.
The best practical reference is the Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment (second edition, 2020), published by Public Health England and the College of General Dentistry. Most of what follows comes from it.
Controlled areas: does your team know where they are?
Every dental X-ray set has a controlled area around it during exposures. The Guidance Notes say the simplest approach is to designate the whole surgery as the controlled area. Where that is not practical for intra-oral equipment, the controlled area can be limited to within 1.5 metres of the X-ray tube and the patient, plus the line of the main beam until it is sufficiently attenuated.
On inspection, I would ask a dental nurse where they stand when an X-ray is taken. A confident answer, matching the local rules and the warning signs on the door, tells me far more than a laminated sheet ever could. Check that:
The controlled area is described in your local rules and agreed with your RPA.
Warning signs and any "X-rays on" lights work and are in the right place.
Staff can explain how they stay out of the controlled area during exposures.
Nobody else (including a parent or carer) is left in the room unless that has been planned and recorded.
Local rules that are read, not just filed
IRR17 requires local rules wherever there is a controlled area. The Guidance Notes list what dental local rules should contain, including:
The dose investigation level.
A summary of the contingency arrangements.
The names of your Radiation Protection Supervisors.
A description of each controlled area.
Key working instructions, and how access to the controlled area is restricted.
The Guidance Notes recommend reviewing local rules at least annually, giving them a version number and issue date, and keeping a record that staff have read and understood them. That last point is where many practices fall down. If a new associate joined six months ago, can you show they have read the current version?
Your Radiation Protection Supervisor
Whenever there is a controlled area, the employer must appoint at least one Radiation Protection Supervisor (RPS), ideally confirmed in writing. The RPS supervises the work so that the local rules are followed. The Guidance Notes are clear that, while the RPS often takes on admin such as equipment testing and record keeping, legal responsibility under IRR17 and IR(ME)R stays with the employer. It cannot be delegated.
When I spoke to an RPS on inspection, I wanted to hear that they understood the local rules, had the authority to stop unsafe practice and knew what to do in an emergency.
Staff doses, pregnant staff and the dose investigation level
The Guidance Notes say annual doses to staff at a well-managed dental practice should be well below 1 mSv. The legal limit for employees is 20 mSv a year, so in normal dental work you are nowhere near it. That does not mean you can ignore doses.
Your radiation risk assessment and local rules must set a dose investigation level. The Guidance Notes say this must not exceed 15 mSv a year, and that 1 mSv a year is an appropriate level for most practices. If a dosimeter result or other evidence suggests a member of staff might reach it, you must investigate.
Pregnant staff often worry about X-rays. Once an employee tells you she is pregnant, the Guidance Notes say the dose to the unborn child must be kept as low as reasonably practicable and is unlikely to exceed 1 mSv for the rest of the pregnancy. The Guidance Notes say that, for most dental practices, no additional controls should be needed if the local rules are followed. Review the risk assessment with her, record the conversation and reassure her with facts. Inspectors are interested in how you supported her, not just whether you did a form.
Contingency plans: what happens when something goes wrong?
Local rules must summarise your contingency plans. The Guidance Notes give examples of foreseeable failures to plan for, including:
The exposure not ending when expected, for example a timer fault.
A panoramic or CBCT unit stopping part way through rotation.
Damage to the tube head or its shielding.
The beam being pointed at someone by mistake, or someone being left in the room.
The loss or theft of a hand-held X-ray unit.
Mythbuster 3 reminds providers that certain over-exposures must be reported to the HSE under IRR17. Patient exposures that are much greater than intended fall under IR(ME)R. I would ask a nurse what they would do if the exposure did not stop. "Switch off at the isolator, tell the RPS and do not use the unit" is the kind of answer I hoped to hear.
Lead aprons and thyroid collars
I still see aprons hanging in surgeries for no clear reason. The Guidance Notes say lead aprons are not needed for routine dental radiography, and thyroid collars are not necessary for staff. Where an apron is used for a specific reason, it should have a lead equivalence of at least 0.25 mm, be checked at least once a year and never be stored folded, because folding cracks the protective layer. If you keep aprons, know why, and record their checks.
Training, audit and evidence
IR(ME)R requires anyone who refers, justifies or takes dental X-rays to be adequately trained for that role. The Guidance Notes repeat the GDC recommendation that dentists and dental care professionals who carry out radiography complete at least five hours of verifiable CPD in radiography and radiation protection in each five-year cycle. Keep certificates on file and check them when staff join.
CQC's Dental mythbuster 17 on audit lists X-ray audit as an essential audit. The Guidance Notes suggest image quality analysis at least every six months, with a sample of at least 100 images where workload allows. An audit with an action plan and a re-audit is strong evidence of good governance under Regulation 17.
A quick self-check before your next inspection
Ask yourself whether each of these is true today:
The controlled area for every X-ray unit is defined, signed and understood by staff.
Local rules are current, version-controlled and signed by every member of the team.
Your RPS is appointed in writing, trained and given time for the role.
The dose investigation level is set and any dosimetry results are reviewed.
Contingency plans are rehearsed, not just written.
Radiography CPD is in date for everyone who takes X-rays.
Image quality audits have action plans and re-audits.
If you are registering a new dental service, CQC's list of supporting documents includes your HSE registration and your radiography risk assessment and local rules. My CQC registration application support can help you get this right first time. You can also download templates and checklists from my free CQC resources page.
Final thoughts
Good radiation protection in dental practices is quiet and routine. Nobody is exposed unnecessarily, the team knows what to do when a unit fails, and the records prove it. When I inspected practices like that, the radiography section took minutes. Make sure yours is one of them.
Comments