Radiation user licence: exemptions and supervision requirements
The Regulation allows certain people to be exempt from holding a licence to use certain regulated materials, subject to requirements specified for the exemption.
Changes to the regulation of radiation
Changes to NSW radiation protection laws commenced 29 August 2025.
Find out about the changes and how they may affect you.
Exemption from holding a user licence for certain types of regulated material
The Protection from Harmful Radiation Regulation 2025 (the Regulation) exempts a person from having to hold a user licence in respect to the following types of regulated material:
- sealed sources specified in Part 1 of Schedule 2 of the Regulation
- radioactive substances and sealed sources specified in Part 2 of Schedule 2 of the Regulation
- ionising radiation apparatus specified in Part 3 and Part 4 of Schedule 2 of the Regulation.
A person who uses regulated material (other than material exempt under Schedule 2) must hold a radiation user licence OR meet the requirements for exemption from holding a user licence.
Obligations of persons responsible, users of regulated material and qualified persons (supervisors)
A person responsible for regulated material must ensure that a person who uses regulated material for which they are responsible:
- holds an appropriate user licence to use that regulated material, or
- meets user licensing exemption requirements for that regulated material and is appropriately supervised where applicable (see table below).
A person who uses regulated material must:
- hold a radiation user licence and comply with any conditions to which the licence is subject, or
- meet the requirements for a user licensing exemption and comply with the appropriate supervision requirements where applicable (see table below) and other obligations.
A radiation user who is responsible for supervising another person using regulated material under an exemption must provide the kind of supervision required under the exemption.
If an employee contravenes any provision of the Act or the Regulation, the employer is also considered to have contravened the same provision.
Who is exempt from requiring a user licence, and supervision requirements for exempt persons
A person is exempt from holding a user licence if they fit into a certain class and use regulated material for certain purposes (listed below) and meet supervision and other requirements.
Approved courses for exemptions will be published on the EPA’s website.
Medical registrars
The exemption for medical registrars other than in the specialties listed in the table below has been removed from the Regulation – specifically, the reference to use of fluoroscopy.
A medical registrar who uses fluoroscopy outside of the listed specialties will need to undertake radiation safety training and obtain a radiation user licence (condition IA22) by 29 May 2026.
A person who is a registrar in this category on 29 August 2025 or who starts their speciality training after that date, will have until 29 May 2026 to complete the radiation safety training and obtain a licence.
Completion of training and a licence will be required for all medical registrars outside of the specialties listed below from 29 May 2026 onwards. Refer to the Licence criteria page for course information.
Exempt classes of persons
The table below shows the classes of persons exempt from holding a user licence and the level of supervision they must be provided in order to meet the exemption requirements.
Exempt persons must also comply with other obligations.
Persons exempt from holding a radiation user licence (An exemption does not have effect unless the person complies with the requirements set out in the Regulation including supervision requirements) | Supervision requirements when an exempt person is using regulated material | |||
|---|---|---|---|---|
| A medical registrar at a hospital and is training in any of the following: | ||||
| Nuclear medicine | Immediate supervision during the first six months of specialty training, and general supervision otherwise. | |||
| Radiology | ||||
| Radiation oncology | ||||
| Ophthalmology | ||||
| Dermatology | ||||
| Rheumatology | ||||
| A student in medical radiation practice training in any of the following: | ||||
| Nuclear medicine | Immediate supervision during clinical experience For diagnostic radiography students in the final 12 months of training during clinical experience: indirect supervision if the qualified person (supervisor) is satisfied the student does not require immediate supervision. General supervision other than during clinical experience | |||
| Diagnostic radiography | ||||
| Radiation oncology | ||||
| A student training in the chiropractic health profession | ||||
| Chiropractic student | Immediate supervision during clinical experience, and general supervision otherwise | |||
| Assistant industrial radiographer | ||||
| An assistant to an industrial radiographer | Immediate supervision | |||
| A student or trainee in a university or other educational organisation undertaking course work or research, who is one of the following | ||||
| Undergraduate student in a university | Immediate supervision | |||
| Vocational student in a registered training organisation | Immediate supervision | |||
| Postgraduate student in a university | Immediate supervision for the first 3 months, and general supervision otherwise. Note: For a postgraduate student who began course work or research before 29 August 2025, general supervision applies. | |||
| Person undertaking a course (approved by the EPA for the purposes of an exemption) with an organisation that is neither a university nor registered training organisation | Immediate supervision | |||
| Registered nurse at a hospital | ||||
| A registered nurse at a hospital who is required to inject radiopharmaceuticals for diagnostic purposes by a nuclear medicine physician when a patient at the hospital experiences a seizure or convulsion or immediately after the seizure or convulsion ends (but only if a person who is the holder of a licence that authorises the injection of radiopharmaceuticals is not readily available at the hospital) | General supervision | |||
| Medical practitioner at a hospital | ||||
| A medical practitioner at a hospital who is required to inject radiopharmaceuticals for diagnostic purposes by a nuclear medicine physician when a patient at the hospital experiences a seizure or convulsion or immediately after the seizure or convulsion ends (but only if a person who is the holder of a licence that authorises the injection of radiopharmaceuticals is not readily available at the hospital) | General supervision | |||
| Dental radiography in relation to use of extra-oral x ray apparatus with intra-oral image receptors for dental diagnostic purposes | ||||
A person registered under the Health Practitioner Regulation National Law to practise in the dental profession (other than as a student) as a dentist, a dental therapist, a dental hygienist or an oral health therapist, and is registered in the corresponding division of that profession, and meets all applicable requirements of the Code of Practice and Safety Guide for Radiation Protection in Dentistry in relation to the use of the apparatus Note: commencing 1 December 2025, dental practitioners will, in addition, be exempt from holding a radiation user licence use for the use of orthopantomogram x-ray apparatus and lateral cephalometric x-ray apparatus for dental diagnostic purposes. | N/A | |||
| A person registered as a student in the dental profession under the Health Practitioner Regulation National Law | Immediate supervision during clinical experience in the course of training, and general supervision otherwise. | |||
From 1 December 2025 A person employed as a dental assistant will be exempt for the use of extra-oral x ray apparatus with intra-oral image receptors, orthopantomogram x-ray apparatus and lateral cephalometric x-ray apparatus for dental diagnostic purposes if they have completed an approved course or already hold a licence that authorises the use of these dental radiation apparatus. | General supervision | |||
| Veterinary radiography | ||||
From 1 December 2025 A person employed as a veterinary nurse, technician or technologist will be exempt for the use of ionising radiation apparatus for veterinary radiography if the use of the apparatus is at the request of a veterinary practitioner and they have completed an approved course or already hold a licence that authorises the use of ionising radiation apparatus for veterinary radiography. | Immediate supervision for equine veterinary radiography General supervision for general veterinary radiography. | |||
Definition of supervision
- general supervision, of a person using regulated material, means the supervision of the person by a qualified person for the purposes of ensuring the person being supervised follows safe radiation work practices for the use of the material.
- immediate supervision, of a person using regulated material, means the supervision of the person:
- by a qualified person who, at all times when the person being supervised uses the material:
- is physically present with the person being supervised, and
- observes and directs the use of the material, and
- for the purposes of ensuring the person being supervised follows safe radiation work practices for the use of the material.
- by a qualified person who, at all times when the person being supervised uses the material:
- indirect supervision, of a person using regulated material, means the supervision of the person:
- by a qualified person who, at all times when the person being supervised uses the material:
- is physically present at the same workplace as the person being supervised, and
- is contactable by ther person being supervised, and
- for the purposes of ensuring the person being supervised follows safe radiation work practices for the use of the material.
- by a qualified person who, at all times when the person being supervised uses the material:
Supervision by a qualified person
A qualified person, in relation to the supervision of a person using regulated material, means an individual who holds a radiation user licence for the use of the regulated material.
Note: In relation to the supervision of a person using radiation apparatus for dental radiography, a qualified person means an individual who is employed as a dentist, dental therapist, dental hygienist or an oral health therapist.
Written exemption approvals no longer required
Under changes to NSW radiation laws from 29 August 2025, a person exempt from the requirement to hold a licence for the use of regulated material does not need to be issued a written exemption approval.
This means that a person who holds a radiation user licence no longer requires or needs to request a General Approval to Exempt from Licensing condition (GE1) on their user licence that permits them to give approvals to certain persons to exempt them from requiring a radiation user licence.
Under the Regulation, the person responsible for regulated material must manage user licence exemption and supervision requirements.
Obligations of exempt persons
In addition to the supervision requirements outlined above, a person exempt from the requirement to hold a user licence for the use of certain regulated material must:
- take all reasonable steps to comply with their organisation's radiation management plan
- not expose a member of the public to ionising radiation that exceeds the dose limits set out in Schedule 4 of the Regulation
- report faults and defects in radiation equipment to the person responsible
- report radiation incidents to the person responsible.
A person exempt from the requirement to hold a user licence for the use of certain regulated material must also take all reasonable steps to comply with:
- the operator requirements (and any other relevant requirements imposed on the person) in a practice-specific national code of practice relating to the radiation practice they are undertaking – see accordion below.
- the requirements set out in AS/NZS 2243.4:2018 that apply to the use of the regulated material within a laboratory environment.
- Medical – Code for Radiation Protection in Medical Exposure (2019)
- Dental – Code for Radiation Protection in Dental Exposure (2025)
- Chiropractic – Code of Practice for Radiation Protection in the Application of Ionizing Radiation by Chiropractors (2009)
- Veterinary – Code of Practice and Safety Guide for Radiation Protection in Veterinary Medicine (2009)
- Industrial radiography – Code of Radiation Protection Requirements for Industrial Radiography (2018)
- Portable density moisture gauges – Code of Practice and Safety Guide for Portable Density/Moisture Gauges Containing Radioactive Sources (2004)