IRMER17 Requirements

When considering the requirements of IRMER17, it’s useful to recall the fifteen written procedures required by regulation 6 and schedule 2 of IRMER17. This article gives more information about these procedures and tells you where you can find some useful resources to help draft them.

IRMER17 – What is Required?

Regulation 6 of IRMER17 requires the employer of the staff working with dental X-ray equipment to have:

• Referral guidelines for medical exposures – these should include the procedure for referral and the selection criteria used
• Protocols for every type of standard radiological practice – these set out the exposure settings for ‘standard’ radiographic examinations

Schedule 2 requires the employer to set down in writing procedures:

• To identify correctly the individual to be exposed to ionising radiation – your arrangements for checking the individual’s identity should be in this procedure
• To identify the individuals entitled to act as referrer or practitioner or operator within a specified scope of practice – as mentioned in step 2.3, the names of those entitled to carry out these roles must be set down in writing
• For making enquiries of individuals of childbearing potential to establish whether the individual is or may be pregnant – not usually required in dental radiography as potential radiation doses to the foetus are very low, but this should still be documented
• For the assessment of patient dose – this should set out how and when patient dose is measured and what to do if ‘non-standard’ exposure factors are used
• For the use and review of diagnostic reference levels (DRL) for radio-diagnostic examinations
• For providing adequate information relating to the benefits and risks associated with the radiation dose from the exposure – this sets out how the patient, or their representative, is given appropriate information
• For the carrying out and recording of a clinical evaluation for each exposure
• To ensure that the probability and magnitude of accidental or unintended exposure to individuals are reduced so far as reasonably practicable – this should set out what steps have been taken to keep the risk as low as reasonably practicable
• To ensure that the relevant people are informed of the occurrence of any relevant clinically significant accidental or unintended exposure, and of the outcome of the analysis of this exposure – this should detail how to conduct an analysis of the accidental exposure, who should be informed and whose responsibility it is to do this
• To establish appropriate dose constraints and guidance for the exposure of carers and comforters
• To ensure that quality assurance programmes in respect of written procedures, written protocols and equipment are followed

Note: schedule 2 identifies two further procedures

• To be observed in the case of non-medical imaging exposures
• For the use of dose constraints for medical research programmes, where no direct medical benefit for the individual is expected from the exposure

Neither of these are likely to be needed in general dental practice, but should they be, the practice should consult its MPE for advice.

Useful templates for all the required procedures can be found in Appendix D of the Dental GNs. These must all be drafted in consultation with the MPE, and should accurately describe the working arrangements at the dental practice.

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.