IRMER17 and X-Rays

In this article we’ll start to look at the requirements of IRMER17, in particular the requirements that you need to consider prior to undertaking any X-ray imaging.

Purpose of IRMER17

The purpose of these regulations is to control radiation doses to individuals undergoing medical radiation exposures and this includes dental X-rays and scans. IRMER17 is regulated in the UK by the following:

• The Care Quality Commission in England
• Healthcare Improvement Scotland
• Healthcare Inspectorate Wales
• The Regulation and Quality Improvement Authority in Northern Ireland

The ‘Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment – 2nd Edition’ was written by a UK working party led by PHE and published in September 2020. The Dental GNs, as we will refer to them, provide practical guidance on how to comply with IRMER17 as they apply to dental radiography. You can access the Dental GNs here.

Following the merger of the FGDP with the College of General Dentistry (CGDent), the Guidance Notes for dental practitioners on the safe use of X-ray equipment (GNs), which are referred to extensively throughout this step have been moved to the CGDent website. If you cannot access the links in this step that take you directly to specific pages in the GNs, please access the Dental GNs here.

IRMER17 Duty Holder Roles

Regulations 4 and 10 of IRMER17 define four categories of duty holder:

• Employer – person who carries out or engages others to carry out medical exposures
• Referrer – person who requests exposure
• Practitioner – person who justifies and authorises exposure
• Operator – person(s) undertaking any practical aspect of radiography (including simple tasks such as patient identification)

The employer must set down in writing the names of those entitled to carry out these roles. As operator duties cover a broad range they must be clearly defined. The table below is taken from the Dental GNs and shows, for conventional radiography, which IRMER17 roles can be undertaken by each registrant group described in the General Dental Council’s ‘’Scope of Practice”. For those undertaking CBCT imaging, section 3.4 of the Dental GNs provides useful guidance.

Click here to access the original table

IRMER17 Training

IRMER17 requires the employer to make sure that all those entitled as practitioners or operators are trained and competent for their role. The Dental GNs also recommend training for those who refer patients for dental CBCT examinations. Records should be kept of all instruction and training provided.

IRMER17 Expert Advice

The employer must appoint a suitable Medical Physics Expert (MPE), to provide advice on compliance with IRMER17. The MPE must also be available for consultation on a number of matters, listed in regulation 14 of IRMER17. More information about the expert advice required by IRMER17 and IRR17 is provided in step 2.4.

IRMER17 Employer’s Procedures

Prior to starting work, the employer must draw up the fourteen written procedures required by schedule 2 of IRMER17. More information on these is given in step 4.9.

Acceptance Testing

Before X-ray equipment is put into clinical use, IRMER17 requires an ‘acceptance test’ to be carried out, to confirm that the equipment is operating correctly and that the radiation dose delivered to patients is suitably restricted. The testing should include the following measurements:

• Operating potential (kV)
• Filtration
• X-ray tube leakage
• Exposure time
• Focus to skin distance
• Field size
• Output linearity and reproducibility
• Patient dose

The MPE must be involved with this testing. In practice, acceptance testing is often carried out at the same time as the critical examination required under IRR17.