Changes to the regulation of radiation

In this section:

• Students and trainees
• Radiation professionals and practitioners
• Obligations of qualified persons (supervisors)
• Obligations of exempt persons
• Licence exemptions – written exemption approvals no longer required
• What you need to do

The Protection from Harmful Radiation Act 1990 requires people who use regulated material to hold a licence.

Regulations made under the Act can exempt radiation users from the requirement to hold a licence and specify conditions when an exemption applies.

The Protection from Harmful Radiation Regulation 2025 makes changes to user licensing exemptions.

The changes are summarised below, with more information found at exemptions and supervision requirements.

Exempt persons should note that penalties may apply for failing to comply with the obligations of exempt persons.

Students and trainees

Students in medical radiation practices who are registered with the Australian Health Practitioners Regulation Agency (AHPRA) remain exempt from user licensing, subject to supervision, compliance with operator requirements in the ARPANSA Medical Exposure Code and other obligations specified in the Regulation.

An important change is that final year medical radiography students may be subject to ‘indirect supervision’ at the discretion of their supervisor.

Registered chiropractic students remain exempt from user licensing subject to supervision, compliance with the operator requirements of the ARPANSA Chiropractic Code and other obligations specified in the Regulation.

Registered dental students remain exempt from user licensing, subject to supervision, compliance with operator requirements in the ARPANSA Dental Code, and other obligations specified in the Regulation.

Dental assistant students undertaking an EPA-approved course are exempt from holding a user licence for dental radiography, subject to supervision requirements, compliance with operator requirements of the ARPANSA Dental Code, and other obligations specified in the Regulation. 

Undergraduate, vocational and postgraduate students not otherwise covered by a specific exemption and persons undertaking an EPA-approved course who use radiation are exempt from user licensing, subject to specified supervision requirements, compliance with operator requirements in the adopted National Directory Code or Australian Standard applicable to the practice, and other obligations specified in the Regulation.

Radiation professionals and practitioners

Medical registrars remain exempt from user licensing for the specialities of dermatology, radiology, nuclear medicine, ophthalmology, radiation oncology, rheumatology, subject to supervision requirements, compliance with operator requirements of the ARPANSA Medical Code, and other obligations specified in the Regulation.

This means that medical registrars in other specialities (for example, cardiology, vascular surgery) will require a licence.

In general, this change will affect medical registrars who use fluoroscopy in specialities other than those listed, and they will have to complete a short course and obtain a licence to use radiation in fluoroscopy. Medical registrars who currently use radiation in fluoroscopy will have until 29 May 2026 to obtain a licence.

Registered nurses and medical practitioners at hospitals remain exempt from user licensing for the injection of radiopharmaceuticals but only in particular circumstances - these being for diagnostic purposes relating to a seizure or convulsion and only as authorised by the prescribing nuclear medical physician.

Registered dental practitioners (dentists, dental therapists, dental hygienists and oral health therapists) who were exempt from licensing for using extra-oral x-ray apparatus when used with intra-oral image receptors under the 2013 Regulation, are now also exempt for the use of orthopantomogram (OPG) x-ray apparatus when used to take an OPG, and lateral cephalometric x-ray apparatus when used to take a lateral cephalometric x-ray, subject to compliance with the ARPANSA Dental Code, and other obligations specified in the Regulation.

The effect of this change is that a dental practitioner will only require a licence when using cone beam computed tomography apparatus.

The exemption for use of OPG and lateral cephalometric apparatus commences on 1 December 2025.

Dental assistants are exempt from holding a radiation user licence for the same activities as dental practitioners referred to above, provided they have completed an EPA-approved course of training, are subject to general supervision, comply with the operator requirements of the ARPANSA Dental Code, and other obligations specified in the Regulation.

A user licence is required for using cone beam computed tomography apparatus.

This exemption provision commences on 1 December 2025.

Veterinary nurses, technicians and technologists are exempt from holding a radiation user licence for veterinary radiography provided they have completed an EPA-approved course of training, use radiation only at the direction of a veterinarian, are subject to supervision requirements, comply with the operator requirements of the ARPANSA Veterinary Code, and other obligations specified in the Regulation.

Note: Veterinary nurses, technicians and technologists require immediate supervision when using radiation apparatus for equine radiography. 

This exemption provision commences on 1 December 2025.

Obligations of qualified persons (supervisors)

If you are a radiation user who is responsible for supervising another person using regulated material under an exemption, you must provide the kind of supervision required under the exemption.

Penalties may apply for non-compliance.

Obligations of exempt persons

In addition to the obligations and conditions outlined above, an exempt person must take all reasonable steps to comply with their organisation’s radiation management plan, report faults and defects in equipment and radiation incidents and comply with dose limits.

Penalties may apply for non-compliance.

Licence exemptions – written exemption approvals no longer required

A person exempt from the requirement to hold a user licence for the use of regulated material does not need to be issued a written approval by a qualified person, as was required under the 2013 Regulation.

Under the 2025 Regulation, the person responsible for the regulated material must manage user licence exemption and supervision requirements, consistent with their obligation to ensure radiation safety in the workplace (see the ‘Information for persons responsible for regulated material’ accordion for further details).

Penalties may apply for non-compliance.

What you need to do

If you are a person in an exempt class, you need to familiarise yourself with the obligations that apply to you in the legislation, and operator requirements in the relevant Code for the radiation practice you are undertaking.

If at the commencement of the exemption provision you are an exempt person in a newly created exemption class (e.g. a registered dental practitioner or a complying dental assistant or veterinary nurse) and you already hold a licence, you may surrender your licence to the EPA. You will not need to renew this licence in future.

If at the commencement of the Regulation you were an exempt medical registrar and continue to use radiation other than in the specified exempt specialities, you should complete the required training and obtain a radiation user licence by 29 May 2026, 9 months after the commencement of the Regulation.

Medical registrars in specialities not covered by exemption starting work after the commencement of the Regulation must complete training and obtain a licence by 29 May 2026.

In this section:

• Comply with adopted National Directory documents
• Prepare a radiation management plan
• Licence exemptions – obligations of radiation management licence holders
• Licence exemptions – certain types of regulated material
• Radiation incident reporting
• Identity check records
• Classification of laboratories
• Fees

Under the Protection from Harmful Radiation Act 1990, a person responsible for regulated material must hold a radiation management licence.

The Regulation imposes obligations on a person responsible who holds a radiation management licence.

Comply with adopted National Directory documents

The Regulation prescribes standard conditions on management licence holders requiring licence holders to comply with adopted National Directory documents (that is, codes and standards listed in Schedule 3 of the National Directory for Radiation Protection adopted by the EPA, subject to the exceptions specified in the Regulation), to make or adopt a radiation management plans for the regulated material and ensure compliance with the plan within their organisation.

The requirement to comply with adopted National Directory documents imports into the Regulation an obligation already a condition of a radiation management licence. The change adds clarity and transparency to management licence holder obligations in this regard.

Find out more about adopted National Directory documents.

Prepare a radiation management plan

Under the 2025 Regulation, all radiation management licence holders who are responsible for regulated material must prepare or adopt and implement a plan that complies with the requirements for radiation management plans in the ARPANSA Planned Exposure Code and any relevant practice specific code that has been adopted by the EPA, subject to the exceptions specified in the Regulation.

Management licence holders must have a radiation management plan in place by 1 September 2026 (12 months after the commencement of the Regulation).

The 2025 Regulation retains the option from the 2013 Regulation for the EPA to direct an employer to prepare and submit a radiation management plan for approval.

Find out more about preparing a radiation management plan.

Licence exemptions – obligations of radiation management licence holders

If a person is in an exempt class with regard to holding a radiation user licence for the use of regulated material for which the management licence holder is the person responsible, the Regulation imposes an obligation on the holder to ensure persons using the regulated material under an exemption meet the requirements for the exemption, and if the person using the regulated material is required to be supervised under the exemption that the person is supervised in the way required under the exemption.

This is a change from the 2013 Regulation, which required an approval to be issued to an exempt person by a qualified person (i.e. a licensee authorised to provide supervision). Now, management licence holders must manage supervision requirements locally.

Penalties may apply for non-compliance.

Find out more about radiation user licence exemptions and supervision requirements.

Licence exemptions – certain types of regulated material

The Regulation prescribes exemptions from the requirements to hold a radiation management licence and/or a radiation user licence for certain types of regulated materials.

The 2025 Regulation makes some minor changes to the exemptions for certain types of radioactive substances, ionising radiation apparatus and sealed source devices.

A person responsible for regulated material should familiarise themself with these exemptions in Schedule 2 of the 2025 Regulation.

Radiation incident reporting

The Regulation requires the reporting of certain radiation incidents to the EPA.

Previously radiation incidents were referred to as radiation accidents.

The 2025 Regulation introduces new descriptions and thresholds for reportable incidents, and the person responsible should familiarise themselves with these descriptions.

An important change is that for certain incidents an estimate of the radiation dose to which a person may have been exposed must be carried out by a medical physicist.

Find out more about reporting radiation incidents.

Identity check records

A small number of licensees are responsible for security enhanced radioactive sources. Special requirements apply to these sources in the Act and Regulation to protect them from unauthorised access and malicious misuse.

A person responsible for security enhanced sources is required to conduct an identity check on certain individuals who deal with a security enhanced source for which the person is responsible.

The 2025 Regulation now specifies that a record of identity checks must be made and kept for 5 years.

Find out more about requirements for persons responsible including identity checks.

Classification of laboratories

The 2025 Regulation requires the classification of a laboratory as a low level laboratory, medium level laboratory or high level laboratory be determined in accordance with the Australian/New Zealand Standard AS/NZS 2243.4:2018 Safety in laboratories, Part 4: Ionizing radiations.

The changes to classification of laboratories more closely aligns the Regulation to the Standard.

Fees

The Regulation makes changes to fees, including:

• increasing the base fee for a radiation management licence
• removing the fee for varying a radiation management licence
• adjusting fees annually by the equivalent of the Consumer Price Index (CPI).

Find out more about radiation management licence fees.

The Regulation sets out responsibilities for employers of occupationally exposed persons. In most cases the employer will also be the person responsible for regulated material who is a radiation management licence holder. See the ‘Information for persons responsible for regulated material’ accordion for further details.

Employer obligations include observing dose limits for occupationally exposed persons, providing personal monitoring to certain occupationally exposed workers and keeping certain records.

The EPA may direct an employer to install area radiation monitoring, appoint a radiation safety officer or a radiation safety committee.

These requirements are unchanged.

Any employer may be required to submit a radiation management plan. For employers who hold a radiation management licence, preparation of a radiation management plan is mandatory as a condition of licence.

The EPA accredits persons under the Protection from Harmful Radiation Act 1990 to carry out certain activities.

The two categories of accredited person are:

• consulting radiation experts who assess equipment against EPA standards for compliance with radiation management licence conditions (currently diagnostic imaging apparatus and fixed radiation gauges), and
• radiation security assessors who endorse security pans required to be prepared by a person responsible for security enhanced radioactive sources.

Condition of accreditation – consulting radiation experts 

The 2025 Regulation now requires as a condition of accreditation that the consulting radiation expert must personally perform the assessments required for certifying compliance with equipment standards.

Renewal of accreditation for certain consulting radiation expert 

A number of consulting radiation experts were issued an accreditation in the initial phase of the accreditation scheme without an expiry date. These accreditations will need to be renewed annually in future. 

Accreditations without an expiry date are set by the Regulation to expire on 1 March 2026, six months after commencement of the Regulation. Affected consulting radiation experts will be sent a renewal notice.

Accreditation fees

The Regulation makes changes to accreditation fees, including:

• increasing the accreditation fee for a consulting radiation expert
• removing the accreditation fee for a radiation security assessor
• adjusting fees annually by the equivalent of the Consumer Price Index (CPI).

The 2025 Regulation provides that the EPA may approve a course of training for the purposes of licensing individuals or exemption from licensing.

A fee for course approvals now applies.

Find out more about applying for course approvals.

Since 2014, the provision of cosmetic ultraviolet (UV) tanning services has been prohibited in NSW.

The 2025 Regulation strengthens the prohibition and increases penalties to discourage non-compliance.

Under the new Regulation, it is an offence for a person or business to:

• operate or provide the use of, or offer to operate or provide the use of, a UV tanning unit for fee or reward, or in connection with other goods, services that are provided for fee or reward, or another benefit, including membership of a club, association or other body, that is provided for fee or reward
• cause or permit another person to contravene the above mentioned prohibition.

In proceedings for an offence, it is presumed, in the absence of evidence to the contrary, that a person has offered to operate or provide the use of a tanning unit for fee or reward if the person publishes a ‘restricted tanning advertisement’, whether or not the advertisement mentions or specifies a fee of cost for the use of a tanning unit.

Find out more about the prohibitions relating to the commercial use of tanning units.