If your dental practice in New South Wales owns or operates X-ray equipment, there's a requirement you need to have met: from 1 September 2026, all radiation management licence holders must have a radiation management plan in place. The requirement comes from the Protection from Harmful Radiation Regulation 2025, which replaced the 2013 regulation.
This guide explains what the requirement means for dental practices, what a plan should contain, and how to get one in place quickly if you haven't yet.
This article is general information. Check the NSW Environment Protection Authority (EPA) guidance and the regulation for your exact obligations, and ask a consulting radiation expert if you're unsure.
Key takeaways
- In NSW, premises that own, store or operate X-ray units, including intraoral, OPG and CBCT units, need a radiation management licence.
- From 1 September 2026, every radiation management licensee must have a radiation management plan.
- You generally don't need to submit the plan to the EPA for approval unless directed, but the EPA can ask to review it and penalties may apply for non-compliance.
- The EPA publishes guidance and templates to help you prepare a plan.
- The plan must be accessible to staff and kept up to date.
Who needs a plan
If your practice holds a radiation management licence, you need a radiation management plan. For dental practices, ADA NSW notes that a radiation management licence is required for premises in NSW that own, store and operate X-ray units. Each dentist or operator also needs the appropriate user licence.
What a radiation management plan covers
According to the NSW EPA, a radiation management plan should:
- Set out the background and operational information needed to work with radiation safely and securely
- Identify foreseeable radiation incidents, and the procedures to prevent them and to minimise the hazards if they occur
- Be easy for staff to access and understand
- Be reviewed and updated when things change
For a dental practice, that typically means documenting:
- The licensee and responsible people, including who manages radiation safety day to day
- An equipment register, listing every X-ray unit with its identification and location, matching your licence
- Compliance testing: when each unit was tested and when it's next due
- Room layouts and shielding, and any shielding assessments
- Who can operate equipment, and their licences and training
- Safe work procedures: justification and optimisation of exposures, protective equipment, and pregnant staff and patients
- Monitoring, such as personal or area monitoring where required
- Incident procedures: what counts as an incident, what to do, and how to report it
- Security of equipment and records
- Disposal of old equipment
- Review dates
Use the EPA's guidance and templates as your starting point. The headings above aren't a substitute for them.
How to get it done
- Download the EPA template and guidance.
- Gather your licence details: management licence, user licences, equipment list and compliance certificates.
- Check your equipment register against your licence. Every unit should be listed with its ID.
- Document procedures for how your team actually uses X-ray equipment.
- Ask your consulting radiation expert to review shielding and testing information.
- Make it accessible: store it where staff can find it, and brief the team.
- Set a review date, and update the plan when you add, move or replace equipment, change rooms or change staff responsibilities.
Other NSW reminders
- Compliance testing: X-ray equipment must be tested by an accredited tester at installation and at the required intervals after that.
- Licences: keep management and user licences current, and update them when equipment changes.
- New equipment: buying a CBCT or OPG? Plan the licensing, shielding and testing steps before installation. See CBCT in general practice.
For practices in other states
Radiation regulation is state-based, so requirements differ. Many states also expect documented radiation safety procedures, so a similar plan is good practice wherever you are. Check with your state regulator.
Frequently asked questions
Do I need to send my plan to the EPA?
According to the EPA, you don't need to submit it for approval unless directed to, but it must be in place and available if requested.
Does this apply to a practice with only intraoral X-ray units?
If the practice holds a radiation management licence for its X-ray equipment, the plan requirement applies.
Who should write the plan?
Usually the licensee or practice manager, using the EPA template, with input from your consulting radiation expert.
Next steps
If your NSW practice doesn't have a radiation management plan yet, download the EPA template today and complete it this week. For more on imaging technology, read our CBCT guide. To free up your practice manager's time for compliance work, see how IntelliDent handles routine calls and bookings.