Register a radiation source

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 (the Act) 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 Act. A registration certificate will be issued once the application has been approved. Please note registration applications may be referred to the Radiation Advisory Committee during the assessment process.

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 in mm Pb (to a minimum of 2 decimal places);
• 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 Plan¹ (RMP) which is specific² to the practice and the ACT, complies with section 33C of the Act, details the procedures for radiation protection at the practice, and includes:

• the name and contact details of the Responsible Person (as defined in the Glossary of RPS C-1), i.e. the possession licence holder, who is the ultimate person/entity solely responsible for radiation safety within their organisation;
• the name and contact details³ (including a phone number, contactable at all times the business is in operation) of the Radiation Safety Officer (RSO), who must be: someone employed to provide daily advice/supervision services on behalf of the organisation; suitably qualified; and reasonably available to attend the site as required, having regard to the attendant risk of the source type(s) at the location;
• 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; and
• 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 assessment of the application 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 section 60 of the Act 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.

¹ Further information is also available in the ‘Radiation Management Plans’ drop-down on this webpage, along with several templates.

² This requirement is in place to ensure that relevant aspects of an organisation’s operating processes are not overlooked through the adoption of a generic template that has not been designed to suit the organisation’s particular needs. The requirement for an RSO to be reasonably available to attend the site is to minimise potential risks to safety and associated impacts upon human health in the event of an incident. The urgency with which attendance is required in any given case will depend on the nature and seriousness of the incident concerned. 

³ This requirement is in place to enable all staff, in the event of an incident, to immediately communicate with the listed RSO.

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 should 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 *the Act) 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 RMP 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.

To comply with section 33C of the Act, a RMP must include the following information:

1. the proposed dealings with the radiation source;
2. the proposed location of the radiation source, including how and where it will be stored;
3. the potential hazards associated with the radiation source;
4. security measures that will be in place to prevent unauthorised dealings with, or access to, the radiation source;
5. the proposed safety measures for dealing with the radiation source, including how the radiation source will be transported or disposed of;
6. details of each radiation safety officer for the plan, including each radiation safety officer’s qualifications in accordance with section 33E of the Act;
7. any other information prescribed by regulation; 

And provide details about how the plan will ensure that dealings with the radiation source:

1. will protect the health and safety of people, property and the environment; and
2. comply with the safety duties under division 3.1 of the Act.
    

A RMP must be submitted with every new registration application. The RMP should be reviewed regularly (at least annually) 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).

Please refer to the ‘Application process’ drop-down for additional information.

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

• Chiropractic
• Dental
• Dental (including CBCT)
• 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 registration application approval will be granted.

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 (2020)
• 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 1: Standard for Limiting Exposure to Radiofrequency Fields - 100 kHz to 300 GHz 
• 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)

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.

Third party verification of installed shielding may be requested by HPS when assessing 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

The following design constraints should 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 HPS

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).

Dental shielding design

The British Institute of Radiology design methodology as indicated in [1] below must be used in radiation shielding calculations for intraoral, OPG and CBCT units in the ACT, along with the design constraints of 40µSv/wk for controlled areas and 10µSv/wk for other areas.

For OPG the required incident air kerma at 1m from the patient is 1µGy per dental image [2]. Variations from this requirement may be considered if sufficient evidence is provided to justify the variation.

For CBCT the incident air kerma at 1m varies with the type of unit and the operating kV. Similarly, the amount of shielding is critically dependant on the kV used. Shielding experts are required to comply with the BIR [1]. The incident air kerma at 1m may be provided by the manufacturer or may need to be determined by measurement.

[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).

[2] HOLROYD, J., Measurement of scattered and transmitted x-rays from intra-oral and panoramic dental x-ray equipment, J Radiol Prot 38 2 (2018) 793-806.

Plasterboard densities

For radiation shielding purposes the density of gypsum plasterboard is assumed to be 0.705g/cm³, as indicated in [1] above. Since plasterboard products with a density lower than this are available on the Australian market, calculation of a density scaling factor is required for any shielding design which specifies a thickness of plasterboard to achieve a particular level of X-ray attenuation.

If the specific plasterboard product which will be used is not known, then the lowest density plasterboard should be assumed for calculation of the scaling factor (currently approximately 0.57g/cm³ which gives a scaling factor of 0.81).

The calculated plasterboard thickness should be divided by the scaling factor to produce an adjusted thickness which takes account of a lower density plasterboard material.

In the absence of a published and peer-reviewed scientific paper, or data from a NATA accredited measurement facility, indicating the X-ray attenuation properties of the particular material at clinically relevant kVp values, plasterboard with a higher density will be assumed to provide only the X‑ray attenuation properties of the ‘standard’ density (0.705g/cm³) material.

Alternative shielding materials

Fyrchek plasterboard

Submission of a shielding plan which includes the specification of this material may result in HPS 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.