Radiation Management Plan
Example Dental Radiography /
Radiation Protection Unit
GPO Box 125
Hobart TAS 7001
03 6166 7256

·  The following Radiation Management Plan (RMP) is an example of the type of information expected in your plan for a dental radiography practice.

·  You should use the red italic text on the front/cover page and in the right hand column as a guide when writing your own plan and replace the red text with your own words.

·  A plan is required under the Radiation Protection Act 2005 and must be approved by the Director of Public Health. The purpose of a plan is to ensure that the practice of dental radiography is conducted safely and in accordance with legislative requirements.

·  Practices are expected to provide general details when describing such items as the practice type and radiation apparatus dealt with, for example:

o  ‘persons authorised under Schedule 3 Part A of the licence’ under point (a)

o  ‘radiation apparatus listed in Schedule 1 Part A of the licence’ under point (b)

This will avoid the need for you to submit an amended Radiation Management Plan each time you add or remove people or radiation apparatus from your licence.

·  Practices are expected to provide specific details when describing such items as courses of study being undertaken, for example:

o  ‘Certificate IV Dental Assisting (Radiography)’ or ‘No students/trainees at present’ under point (h).

·  A plan may be supported by practice protocols and procedures, which can be referenced in the plan but do not need to be submitted with the plan.

·  A plan should be reviewed by the practice either annually or biannually, and the date for the next review should be recorded on the front/cover page.

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Radiation Management Plan

For: Dr Penny Caries

(applicant for licence to possess/licence holder)

holder of licence L000195 to possess radiation apparatus

of: Caries Dental Services

(organisation/company/trading name – as applicable)

for the practice of: Dental Radiography

to be carried out at: 2 Mineral Street, Burnie and 51 Molar Avenue, Devonport

Plan prepared by: Dr Daniel Caries (RSO)

Date: 30 April 2015

Contact details:

Telephone: 03 6432 1000

Facsimile: 03 6432 1111

Email:

Plan accepted by Dr Penny Caries (applicant/licence holder)
who hereby agrees to adhere to all requirements in the plan.

Signature: P Caries

Date: 30 April 2015

Date for review: 30 April 2017

(date when it is intended the plan will be reviewed eg in one or two years’ time)


Introduction

This plan has been prepared in accordance with Regulation 8 of the Radiation Protection Regulations 2006. This plan will ensure the practice of dental radiography is conducted as safely as possible and in compliance with the Radiation Protection Act 2005 and the Radiation Protection Regulations 2006.

Compliance with this radiation management plan will help ensure the radiation doses to users, other persons involved in the practice, members of the public and the environment are below the prescribed limits and are as low as reasonably achievable. It will also help ensure that the number of people exposed to radiation and the likelihood of unexpected exposure to radiation are minimised.

The plan is to be read by everyone in Caries Dental Services.

Information required by
Regulation 8,
Radiation Protection Regulations 2006 /

Details of plan

(a) a brief description of the type and scope of the radiation practice / Radiography in dental practice – intra-oral and OPG units in two premises (Certificates of Registration for Place AP/nnn & AP/mmm) as per Schedule 1 Part A of the licence. The x-ray units are operated by persons authorised on Schedule 3 Part A of the licence.
(b) a list of the radiation apparatus dealt with in the radiation practice / As per Schedule 1 Part A of the licence.
(c) an assessment of the potential hazards from the radiation apparatus dealt with in the radiation practice / Exposure to radiation from direct beam, scattered radiation; radiation from tube head leakage.
(d) details of the environment likely to be exposed to radiation during the radiation practice / Dental surgeries and adjacent rooms.
(e) the radiation principles, work practices (including quality-assurance procedures) and equipment (including personal radiation monitors) used to ensure that radiation exposure of persons or the environment is as low as is reasonably achievable during typical types of work carried out within the radiation practice / Practice applies the principles for radiation protection outlined in the “Fundamentals for Protection Against Ionizing Radiation”[1]
Radiographs taken only if clinically justified; workloads specified in the Certificate of Registration for the places are adhered to; use fastest film speed available; adhere to CoP[2];
operators trained and authorised on licence; use time/distance/shielding to minimise the dose to operators.
Personal monitor used as area monitor for each surgery.
QA protocol developed and available for x-ray imaging systems, including recording and investigating repeat radiographs and any radiographs not in accordance with the imaging request.
(f) details of the classes of persons likely to be exposed to radiation during the radiation practice, including
(i) children / Written procedures implement Section 6 of the CoP. These written procedures require that child patients are only radiographed if absolutely essential for clinical purposes and then optimum exposure factors must be used; other children to be out of surgery if possible; if a child must remain in a surgery then they must be at least 2 metres from the x-ray unit and shielded with a protective apron.
(ii) pregnant women / Such an operator may be involved in radiography but only if wearing protective clothing, standing at least 2 metres from x-ray tube, and if exposure to foetus will not exceed public dose limit. Practice takes fewer than 50 radiographs per week at each premise and so this limit will not be exceeded with above protective measures in place.
Pregnant patients – provide lead apron for radiographs directed downwards.
(iii) volunteers in biomedical research / Not relevant for this dental practice.
(iv) persons exempt from section 13(1) of the Act under Part 10 / Dental assistants undertaking Cert IV training must not remain in the surgery while x-rays are being taken.
OR
No students/trainees at present.
Other persons: / Persons authorised on the licence to ‘use’ the x-ray units and dental assistants must not remain in the surgery while x-rays are being taken.
(g) the maximum dose of radiation it is anticipated a person of a class of persons specified in paragraph (f) will receive while the radiation principles, work practices and equipment referred to in paragraph (e) are being used, and the action to be taken if those doses are exceeded / Personal monitors should indicate less than
50 µSv per three-month period for a well-run dental practice).
Will immediately review practices and notify Director of Public Health (DPH) if doses above this level are recorded.
(h) details of a course of study or training that
(i) is being or will be undertaken by a person who is expected to be dealing with a radiation source in the radiation practice
(ii) requires, as part of that course of study or training, the person to deal with the radiation source in the radiation practice / Dental Assistants may undertake Certificate IV Dental Assisting (Radiography) through an approved institution (e.g. TAFE South Australia or Skills Tasmania)
The practical component of the course is conducted at the OHS Tasmania training facility, under the supervision of (Name), (Position), (Quals) and in this practice.
(i)  the name, qualifications and experience of the supervisor of a person referred to in paragraph (h)(i) while undertaking that part of a course of study or training referred to in paragraph (h)(ii) / Dr Penny Caries (BDS), registered Dentist, 20 years’ experience.
OR
Not applicable at present.
(j) the training and information to be provided to persons involved in carrying out the radiation practice / In-house radiation safety awareness training for ALL staff; staff assisting with radiography to read CoP, the ‘Fundamentals’[3] and the National Standard[4] and licence conditions and demonstrate an understanding of the requirements in these.
(k) the name and contact details of the radiation safety officer for the radiation practice / Dr Daniel Caries, BDS
Phone: 03 6432 1000
Fax: 03 6432 1111
Email:
(l) a brief description of the role of the radiation safety officer / Sections a – n of 2.1.4 in CoP;
list attached at end of this plan.
Ensure personal monitoring conducted appropriately and that monitors are stored with the control when not in use.
(m) a brief description of the resources available to the radiation safety officer to enable him or her to perform his or her role under the radiation management plan / Budget includes funding for personal radiation monitoring, QA program, replacement of protective clothing, compliance testing, staff radiation protection training.
RSO has ready access to this plan, the licence document, the Certificate of Registration for the place, and all referenced documents.
(n) a description of the roles and responsibilities, that are relevant to a
dealing with the radiation source in the radiation practice, of all persons
authorised by the licence to deal with the radiation apparatus in the radiation practice / Licence holder: ensure this plan is implemented.
RSO: see above.
Operators named on licence: as per licence conditions.
Other staff: obey warning signs and written instructions (developed and placed in prominent location in surgery) aimed at minimising their exposure to radiation.
(o) the methods used to ensure that the persons referred to in paragraph (n) are aware of their obligations under the Act and the licence / Radiation safety awareness training includes provision of information about the licence and its conditions.
(p) details of how the radiation apparatus in the radiation practice will be prepared for use, repaired, maintained, transported, stored and disposed of / X-ray units to be checked by service engineer for mechanical and electrical safety on an annual basis; compliance checks every four years.
When no longer required, will seek an amendment to the licence to dispose of an x-ray unit such that it
a)  is sold, or
b)  cannot be reassembled for use
in accordance with Regulation 19.
(q) details of any emergency response plans for the radiation practice including reporting to the Director of Public Health / X-ray unit will be switched off/unplugged immediately if aberrant radiation output suspected. DPH will be informed of any malfunction of the x-ray unit that could have resulted in unexpected irradiation of any person or of any situation where a person could have been exposed inadvertently.
(r) details of procedures that are designed to minimise the radiation hazard arising from a radiation incident / X-ray unit will be switched off/unplugged immediately if aberrant radiation output suspected.
(s) details of reporting procedures for incidents adversely affecting, or likely to adversely affect
(i) equipment used in the radiation practice
(ii) the environment
(iii) the health or safety of any person / Staff are required to report any malfunction of an x-ray unit/observed damage to unit (e.g. frayed cords, dents in tube casing) to RSO immediately. Any other incident also to be reported to RSO who will take immediate action and pass on information to Dr Penny Caries (licence holder) for any necessary further investigation and action, including reporting to the DPH.
(t) details of record-keeping requirements including details of the records that will be kept of movement of any mobile radiation source in the radiation practice / Records of all radiographs will be maintained for at least seven years and will indicate the operator, exposure factors, patient and view. Record of disposal of unit will be maintained as per Regulation 26, Radiation Protection Regulations 2006.
(u) details of the use of radiation warning signs and labels in the radiation practice. / Warning labels on the x-ray units, as per the CoP and Certificate of Registration for the place.


Referenced documents:

·  CoP: ARPANSA The Code of Practice for Radiation Protection in Dentistry (2005)

·  RPS1: National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the Chief Executive Officer of ARPANSA

·  Fundamentals: ARPANSA Fundamentals for Protection Against Ionising Radiation (2014)

·  Radiation Protection Regulations 2006

·  Radiation Protection Act 2005

Attached documents:

·  Duties of the RSO


Duties of the RSO:

The RSO will:

a)  supervise the radiation protection aspects of the radiation practice that are specified in the radiation management plan

b)  operate and interpret the readings from radiation monitoring equipment that is required for the radiation practice

c)  understand the precautions (including the use of protective clothing and equipment) to be taken in carrying out the radiation practice

d)  understand the extent to which the precautions referred to in paragraph (c) will restrict exposure to radiation

e)  know the actions required to carry out the emergency procedures specified in the radiation management plan

f)  help the holder of the licence implement the employer’s duties specified in Chapter 5 of the National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the Chief Executive Officer of ARPANSA

g)  carry out the duties specified for a radiation safety officer in the Code of Practice for Radiation Protection in Dentistry (2005), and the National standard for limiting occupational exposure to ionizing radiation.

1

[1] ARPANSA Fundamentals for Protection Against Ionizing Radiation (2014)

[2] ARPANSA Code of Practice for Radiation Protection in Dentistry (2005) RPS10

[3] Fundamentals for Protection Against Ionizing Radiation (2014)

[4] National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the Chief Executive Officer of ARPANSA