Radiation management plans

Under the Protection from Harmful Radiation Regulation 2025, organisations responsible for radiation practices must have a radiation management plan in place from 1 September 2026.

A radiation management plan establishes procedures and provides safety information for anyone working with or around radiation sources in your organisation to protect people and the environment from the harmful effects of the radiation.

A radiation management plan outlines how an organisation will safely and responsibly manage radiation apparatus and radioactive substances.

A radiation management plan should:

• detail the necessary background and operational information for working with radiation in a safe and secure way and how an organisation will manage the equipment and risks associated with radiation
• identify the radiation incidents that could happen and detail the processes and procedures in place to minimise the potential hazards
• be readily available and easily understood by all people working with or around the radiation sources in the radiation practice
• be implemented, regularly reviewed and updated whenever any changes have occurred.

Who needs a radiation management plan

Radiation management licensees

All radiation management licensees are required to have a radiation management plan by 1 September 2026.

Under recent changes to NSW radiation legislation, it will become a condition of a radiation management licence that the person responsible for regulated material must ensure that a radiation management plan relating to the regulated material is prepared or adopted and implemented.

You do not need to submit your radiation management plan to the EPA for approval unless directed to do so.

Radiation management plans, however, may be reviewed by the EPA at any time, including as part of compliance and enforcement programs.

Penalties may apply for non-compliance.

Other employers

Not all radiation practices require a radiation management licence, for example, milling and mining activities.

The EPA or the Department of Primary Industries and Regional Development (regulator of mining activities) may direct an employer, who is not a licence holder, to prepare and submit a radiation management plan for approval.

Penalties may apply for non-compliance.

Requirements

Radiation management plans must comply with the requirements for the preparation of radiation management plans outlined in national codes published by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) and adopted by the EPA.

Your plan must comply with the requirements for plans contained in the: 

• Code of Practice for Radiation Protection in Planned Exposure Situations (2020), and
• any practice-specific national code of practice relevant to your radiation practice – see accordion below.

A plan should also conform to the requirements of the Protection from Harmful Radiation Regulation 2025, for example, it should use the required units of measurement, such as SI units, and apply the correct system of dose limitation.

Preparing a plan

Radiation management licensees without an existing plan

Radiation protection requirements are unique for each situation, with protection measures commensurate with the level of radiation risk associated with your activities and/or sources of radiation.

You must prepare a plan that is appropriate to your radiation practice and circumstances and meets the requirements outlined above.

A radiation management plan may be prepared by the organisation, a consultant or an associated interstate or overseas organisation.

You will need to have a plan in place by 1 September 2026.

Note: The EPA may, at any time, direct an employer to prepare or adopt a radiation management plan and submit it for approval.

Radiation management licensees with an existing plan

Many management licensees already voluntarily have a radiation management plan, while some licensees may have previously been directed to prepare a plan. 

Licensees with an existing plan will need to review their plans to ensure their plan meets the requirements outlined above by 1 September 2026.

Employers (who do not hold a radiation management licence)

Employers that are directed by the EPA or the Department of Primary Industries and Regional Development to prepare and submit a radiation management plan for approval must ensure that the plan meets the above outlined radiation management plan requirements.

Templates

The EPA is developing templates to assist some low-risk radiation practices to prepare a radiation management plan. These will be made available on this web page.

Obligations of licensees and employers

Radiation management licensees and employers with a radiation management plan must:

• implement the plan
• regularly review the plan
• ensure a copy of the plan is available to all radiation users and occupationally exposed persons in their organisation, and
• take all reasonable steps to ensure the procedures set out in the plan are followed by radiation users and occupationally exposed persons.

Penalties may apply for non-compliance.