Register a radiation source

The Radiation Protection Act 2006 requires that radiation apparatus and sealed sources are registered. This includes any regulated radiation sources in your possession that are not operational or not in use. Anyone who deals with a radiation source must also be licensed.

Categories of radiation sources that require registration include:

• X-ray apparatus
• sealed radiation sources
• apparatus that includes a sealed radiation source
• accelerated particle beam apparatus

In order to register a source, a company or individual must first hold a licence to possess the source. 

Existing registrations must be renewed prior to expiry, unless the source is no longer in your possession and you have lodged a transfer of ownership application or a notification of disposal form with the Health Protection Service (HPS).

Application process

You should prepare your application as soon as you have decided to acquire a radiation source, and lodge it no later than 7 days after taking ownership of the source. (It is an offence under s60 of the Radiation Protection Act 2006 if a person fails to apply to register a radiation source within 7 days of acquiring ownership of the source).

Exact source details such as serial numbers can be provided at a later stage if they are not available at the time the application is lodged.

Please follow the application steps below:

1. use the online form or download the Radiation Source Registration application form
2. complete and sign the application form
3. submit the form with the appropriate documentation and fee to the Health Protection Service (HPS) (see the ‘Required information/documentation’ below). A receipt will be provided, confirming your application and payment. (Please be advised that you may not be able to lodge your application without all of the required documentation).
   A third-party compliance test is also required for X-ray equipment. HPS will arrange this for you after the registration application has been lodged

The source may not be used until such time as the registration has been approved under s26 of the Radiation Protection Act 2006. A registration certificate will be issued once the application has been approved.

The Radiation Council may consider registration applications out of session in exceptional circumstances. This does not include applications submitted at short notice or after a source has been installed.

In order to be considered by the Radiation Council, the following information/documentation is required as part of the Source Registration Application.

Required information/documentation:

1. A possession licence in the same name as the equipment owner, and licensed to possess the type of source for which the source registration is sought.
2. A floorplan, to scale including room dimensions.
3. A shielding plan, designed using current ACT design constraints and shielding height requirements (as shown in the ‘Shielding plan’ section of the website below), including but not limited to:

• the source location and orientation;
• the operator position;
• workload given as exposures per week and mA.min/wk; and
• calculation tables, including the distance to the barrier and the occupancy factor of adjacent areas, with the resultant lead (Pb) equivalence requirement and how this may be achieved with alternative materials.

4. Shielding verification, i.e. verification that the installed shielding meets or exceeds the requirements of the shielding plan, including how penetrations of the shielding material have been addressed to ensure continuity of shielding. (If information about the nature and thickness of the installed materials cannot be obtained by the source owner, then a Shielding Survey Report may be submitted).

If a Shielding Survey Report is provided it must contain:

• the workload against which the suitability of the installed shielding has been assessed;
• the distance to each barrier;
• the dose rate measurements (including the measurement position and height from floor level);
• calculation of the Pb equivalence of each barrier;
• evidence of assessment of all potentially weak points in the shielding, including: penetrations for power points, light switches, electrical wiring, or plumbing; doors and windows (including the frames).

5. A Radiation Management Plan (RMP) which is specific to the practice and includes procedures for radiation protection and:

• the name and contact details (including phone number) of the Radiation Safety Officer (RSO), who must be: someone within the organisation; suitably qualified and located within the ACT; available to immediately attend the site if required; and the holder of a current ACT Radiation user licence;
• a current list of radiation sources within the practice, including the source for which registration is being sought;
• a current list of licensed users for each radiation source within the practice.
• an explanation and evidence of how Personal Radiation Monitoring (PRM) is being achieved within the practice.

6. Evidence that visual contact with the patient can be maintained from a shielded operator position throughout the X-ray exposure, e.g. via a Pb equivalent viewing window, or indirectly via a strategically placed mirror to enable an indirect view, or via a CCTV setup.
7. Barrier tagging of the operator barrier, including the viewing window if applicable, and any other appropriate walls/windows/doors (with the lead (Pb) thickness or the Pb equivalence and relevant kV).
8. The calibration certificate for each sealed source or Portable Density Moisture Gauge (PDMG).

A compliance inspection report is required for each X-ray apparatus, and since this will be arranged by HPS it does not need to be included when the application is lodged.

If any information, other than the compliance inspection report, is not provided at the time of lodgement then consideration of the application by the Radiation Council may be delayed until the information is provided.

 When arranging the timing of prospective purchases, consideration should be made of the required information, and of s60 of the Radiation Protection Act 2006 which requires that an application for registration be lodged no later than seven (7) days after taking possession of the source.

Additional requirements exist for accelerated particle beam apparatus. Please contact HPS at your earliest opportunity for details of these requirements.

For security enhanced sources a Security Management Plan is also required.

A Radiation Management Plan (RMP) must be developed for each practice. The RMP must be available to all people who might deal with the radiation source. The RMP must be reviewed at least annually to ensure that it is up to date.

The RMP is the primary document that describes how a radiation source is dealt with, by whom, and the procedures that manage the source and radiation exposures to people.

The RMP is a document that describes how compliance with the legal obligations under the Radiation Protection Act 2006 and associated documents will be achieved at your workplace. This includes documents in the ARPANSA Radiation Protection Series (RPS), publications such as the National Directory for Radiation Protection, June 2017 (RPS6), relevant Codes of Practice, and Australian Standards. The Radiation Management Plan will detail how exposures to both workers and the public will be kept below established dose limits and as low as reasonably achievable (ALARA). The RMP should also include disposal considerations and should include processes and procedures for dealing with incidents, accidents and emergency response.

A RMP must be submitted with every new registration application. The RMP should be reviewed regularly and updated whenever any changes have occurred such as changes in procedures, staff or equipment, and an updated RMP should be submitted with registration reapplications (renewals).

Should you require assistance in developing your RMP, several templates are provided which cover the following use of regulated radiation sources:

• Chiropractic
• Dental
• Portable density moisture gauging
• Veterinary

These templates are designed as an aid to the development of a Radiation Management Plan only. The template may not apply to your company or organisation. As the radiation protection requirements are unique for each situation, a plan which is appropriate to your situation must be prepared. ACT Health does not take responsibility or liability for any protection measures in this template. The use of the template does not imply that approval will be granted, applications are assessed by the Radiation Council.

Please consult the following documents when developing your RMP:

• Code of Practice for Radiation Protection in Medical Applications of Ionizing Radiation
• Code of Practice and Safety Guide for Radiation Protection in Veterinary Medicine
• Radiation Protection in the Application of Ionizing Radiation by Chiropractors
• Radiation Protection in Dentistry
• Code of Practice for Portable Density/Moisture Gauges Containing Radioactive Sources
• Safe Use of Fixed Radiation Gauges
• RPS C-1: Code for Radiation Protection in Planned Exposure Situations (2016)
• RPS C-2: Code for the Safe Transport of Radioactive Material (2019)
• RPS C-3: Code for Disposal Facilities for Solid Radioactive Waste (2018)
• RPS C-4: Code of Radiation Protection Requirements for Industrial Radiography (2018)
• RPS C-6: Code for Disposal of Radioactive Waste by the User (2018)
• RPS 3: Radiation Protection Standard for Maximum Exposure Levels to Radiofrequency Fields – 3kHz to 300GHz (2002)
• RPS 5: Code of Practice and Safety Guide for Portable Density/Moisture Gauges Containing Radioactive Sources (2004)
• RPS 8: Code of Practice for the Exposure of Humans to Ionizing Radiation for Research Purposes (2005)
• RPS 9: Code of Practice and Safety Guide for Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing (2005)
• RPS 10: Code of Practice and Safety Guide for Radiation Protection in Dentistry (2005)
• RPS 11: Code of Practice for the Security of Radioactive Sources (2019)
• RPS 12: Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006)
• RPS 13: Code of Practice and Safety Guide for Safe Use of Fixed Radiation Gauges (2007)
• RPS 14: Code of Practice for Radiation Protection in the Medical Applications of Ionizing Radiation (2008)
• RPS 17: Code of Practice and Safety Guide for Radiation Protection in Veterinary Medicine (2009)
• RPS 19: Code of Practice for Radiation Protection in the Application of Ionizing Radiation by Chiropractors (2009)
• RHS 31: Code of Practice for the Safe Use of Industrial Radiography Equipment (1989) – this has been superseded by RPS C-4

The RMP may apply to an entire organisation or premises. However, it should specifically address each registered radiation source, including a list of registered sources and a list of licensed users.

You may reference your supporting safety documentation in the RMP.

If your work includes transporting sources you need to prepare a Transport Management Plan (TMP) and ensure that your radiation licence specifically permits this as a dealing.

The TMP may be part of your Radiation Management Plan or it may be a separate document.

A template is provided to assist you in developing your Transport Management Plan. ACT Health does not take responsibility or liability for any protection measures in this template. 

A shielding plan is a document which details the level of shielding that is, or will be, installed in order to protect workers and members of the public. This could include dental, veterinary, chiropractic, or other medical premises where ionising radiation apparatus is used. The plan will typically include floor plans, estimated dose calculations and other details related to radiation protection.

Where a radiation source is used it is a requirement that radiation shielding be documented as part of commissioning and where shielding modifications are made subsequent to commissioning.

Any source that will be installed in new or renovated premises must have a radiation shielding plan prepared and submitted with the registration application. Where a replacement source is installed into existing premises which have not been renovated submitting a copy of the existing shielding plan will generally be sufficient.

To ensure that the shielding plan meets all relevant requirements, it should be submitted as early as possible and prior to construction. The radiation shielding needs to be inspected by HPS during the construction phase before it is covered by paint, plaster, floor coverings or other fittings – or must be tested by accredited testers.

Any penetrations to the shielding, such as for cables, power points, water pipes or light switches, need to be addressed with material equal to or greater than the lead equivalence of the material which was removed.

The additional material needs to extend beyond the edges of the penetration by at least twice the offset distance*. If the location of a stud or nogging makes this impossible the additional material must return along the stud or nogging to meet the original layer of material.

*The offset distance is the distance between the original material and the additional material.

The Radiation Council may request third party verification of installed shielding when considering a source registration application or re-application (renewal).

For further information contact the Health Protection Service, and consult the following documents: National Directory for Radiation Protection, June 2017 (RPS 6), Radiation Protection in Planned Exposure Situations (2016) (RPS C-1), Fundamentals for Protection Against Ionising Radiation (2014) (RPS F-1), and any relevant RPS publication, e.g. Code of Practice for Radiation Protection in the Medical Applications of Ionizing Radiation (2008) (RPS14). The National Council on Radiation Protection and Measurements (NCRP) Report No. 147, Structural Shielding Design for Medical X-Ray Imaging Facilities may also be useful.

Design Constraints

Following a decision made by the ACT Radiation Council, in a move towards national uniformity, please note the following design constraints which should now be used in radiation shielding calculations:

• Controlled areas 2mSv/yr (40µSv/wk)
• Other areas 0.5mSv/yr (10µSv/wk)

A controlled area, in relation to a radiation source, is a limited access area:

• in which the exposure of persons to radiation is under the supervision of an individual in charge of radiation protection. This implies that access, occupancy and working conditions are controlled for radiation protection purposes; OR
• to which access is subject to control and in which employees are required to follow specific procedures aimed at controlling or monitoring exposure to radiation.

If a blanket design constraint is used for an entire practice or department then this should be 0.5mSv/yr (10µSv/wk).

Shielding design height requirements from the finished floor level are:

• no less than 2.1m for general radiography, fluoroscopy, mammography, BMD/DEXA, OPG, intraoral, dental CBCT and nuclear medicine; and 
• no less than 2.7m or to the upper slab, whichever is the lower for CT, including SPECT/CT, PET/CT and all other non-dental CBCT unless a lower height has been authorised by the Radiation Council.
  However, for high dose areas including CT and interventional radiology, shielding design depends on a number of site-specific factors so shielding designers are asked to refer to authoritative texts which deal with these cases such as [1] and to specify height requirements greater than those indicated above, where applicable.
  [1] Sutton, D.G., Martin, C.J., Williams, J.R., Peet, D.J., Radiation Shielding for Diagnostic Radiology, 2nd Edition, British Institute of Radiology, London (2012).

Alternative shielding materials

Fyrchek plasterboard

It has come to the attention of the ACT Radiation Council (the Council) that some shielding designers have been specifying this as an alternative shielding material. Submission of a shielding plan which includes the specification of this material may result in the Council requesting supporting information in relation to the X-ray attenuation properties of the material. The supporting information must be in the form of a published and peer-reviewed scientific paper that details the use of relevant thicknesses of this material at various kVp values.

The Security Plan applies to high activity sealed sources or apparatus that incorporates sealed sources only.

The Code of Practice for the Security of Radioactive Sources (2019) (RPS 11) categorises and sets security requirements for these sources. Category 1, 2 and 3 sources are considered security enhanced sources that require a greater level of security and protection. You must submit a Security Management Plan before registration for these categories of sources.

You must provide a notification of service (installation) before installation of a new machine. Your installer can provide you with a copy of this.

X-ray apparatus must comply with mandatory requirements about performance, quality and safety before it can be registered. We can arrange for compliance testing to occur after installation.

Applications are notified about any issues that arise during this process. Remedial action is required before the registration can progress.

Notify Online or download the Installation, service or repair of a regulated radiation source Notification form.

Following a tube change a full service report must be submitted to HPS, indicating that the equipment has been tested and meets the relevant Australian Standards.

Provided this report has been submitted to HPS, the equipment can then go back into clinical operation.