Develop a radiation safety and protection plan

Radiation Safety and Protection Plans (Plans) need to be purpose built and tailored for the business, as no two businesses are the same.

Corporations or individuals that seek to possess radiation sources need a Plan, approved by Radiation Health, for their radiation practice. The Plan specifies the actions taken to protect people and the environment from the harmful effects of the radiation used in the radiation practice.

When to develop a Radiation Safety and Protection Plan

If you apply for a Possession Licence, you will need to submit a Plan for the radiation practice. Make sure the Plan is clear and thorough as your Possession Licence cannot be granted until the Plan is approved. The plan needs to be readily available and easily understood by all people involved with the radiation sources in the radiation business.

Why a Radiation Safety and Protection Plan is needed

The Plan is the primary radiation management document that will guide how you and your staff implement safe practices in your radiation business. It details the specific radiation safety requirements for your radiation practice and outlines how you will:

  • protect people from the health risks associated with exposure to the radiation used in your radiation practice
  • protect the surrounding environment from the negative effects of the radiation used in your radiation practice.

The information detailed in the Plan will govern how:

  • the organisation and staff operate to ensure the safety of anyone involved in your business
  • the Possession Licensee controls the radiation source, including who can access the radiation source and when
  • the Use Licensees operate the radiation source and when
  • the Radiation Safety Officer ensures radiation safety measures stay effective and monitors compliance with the Radiation Safety Act 1999 and Plan
  • the records are kept, what records need to be kept and who is responsible.

Develop a Radiation Safety and Protection Plan

There are 4 main sections a Plan needs to cover:

  1. Identify radiation hazards
  2. How radiation hazards will be managed
  3. Ensure safety measures stay effective
  4. Incident response.

You may wish to get assistance from a consultant when preparing the Plan for your specific radiation practice

There are Codes of Practice and safety guides to help you develop the Plan for your specific radiation practice.

1. Identify radiation hazards

What is the worst-case health and safety threat posed by using radiation sources in your business?

Identify the radiation hazards specific to your radiation practice, including:

  • a description of what you are possessing the radiation source for (your radiation practice type)
  • the types of radiation sources that will be used
  • an assessment of the hazards specific to your radiation source and practice type.

2. How radiation hazards will be managed

What radiation safety methods and procedures are staff required to follow?

Detail how you will prevent or minimise health risks to anyone involved in your radiation practice who may be exposed to radiation.

Your plan must detail how the radiation hazard will be managed, including the following information:

Control access to radiation sources and equipment

How you will prevent unauthorised access to the radiation source?

Both physical barriers and internal processes may be needed to ensure only authorised people can use, control or conduct servicing of the radiation sources. These should be detailed in your Plan.

For example, rooms that contain radiation sources have locked access points that only authorised staff can open. Staff are required to follow a specified approval process to be allowed to perform a particular radiation procedure on a patient or client.

Conduct compliance testing and maintenance

What routine maintenance will occur to check that the radiation source is operating safely and correctly?

Detail the quality control procedures (routine checks) and maintenance procedures in place to ensure that radiation sources continue to operate correctly and comply with the relevant safety standard.

Your Plan should include:

  • what the radiation source is
  • the safety standards relevant to your radiation practice (for radiation sources, equipment and premises)
  • when compliance testing and maintenance will occur on the equipment
  • the qualifications or abilities the person checking the equipment needs.

You should provide a compliance testing and maintenance register and require Use Licensees to record:

  • the results of the quality control and maintenance procedures
  • any comments and recommendations to ensure the safe use of the radiation sources
  • any actions taken in response to the recommendations.

Provide personal protective equipment

What personal protective equipment will be provided to the people involved with the radiation source?

Personal protective equipment is equipment that may be worn by persons performing a radiation practice to reduce their exposure to radiation. It is also needed for the customers or patients being exposed to radiation for:

  • diagnostic procedures
  • therapeutic procedures
  • cosmetic services.

Personal protective equipment may include:

  • lead aprons
  • gloves
  • overshoes
  • eyewear.

Your plan should detail:

  • the personal protective equipment available in your business
  • who you will require to wear the equipment
  • how and when the equipment is to be worn
  • when compliance testing and maintenance will occur on the equipment
  • the qualifications or abilities the person checking the equipment needs
  • any instructions for Use Licensees to ensure that the customer or patient wears the equipment.

Provide radiation safety devices

What radiation safety devices will be provided to minimise radiation exposure?

A safety device is any piece of equipment used to reduce the radiation exposure of a user, member of the public or other person. It is not personal protective equipment.

For example, for diagnostic radiography safety devices may reduce the need for repeat exposures or may remove the need for someone to hold a patient during exposures.

Your plan should include:

  • the radiation safety devices available at the radiation practice
  • how and when the devices are to be used
  • when compliance testing and maintenance will occur on the devices
  • the qualifications or abilities the person checking the devices needs to have.

Examples of safety devices include:

  • moveable lead shields
  • perspex work stations
  • animal control or restraining devices
  • handling tongs and lead shot
  • foam pads and sandbags
  • tools that do not reflect light.

If these devices are unnecessary in your business, your plan should state why they are not needed.

Requirements for specific radiation sources and practices

Some radiation sources and practices have additional management requirements. You only need to include these requirements in your Plan if they are applicable to your specific radiation practice.

Requirements for specific radiation sources and practices detail the additional requirements for:

  • Medical radiation businesses
  • Dental radiation businesses
  • Chiropractic radiography businesses
  • Veterinary radiation businesses
  • Industrial radiography businesses
  • Borehole logging businesses
  • Education, science or research radiation businesses
  • Compliance testing, servicing or calibration businesses.

3. Ensure radiation safety measures stay effective

What will you do to ensure that your safety measures stay effective?

Your plan must detail the procedures and processes in your business that will ensure the health and safety measures in your Plan are being followed and remain effective.

It must also detail how you propose to monitor and review the effectiveness of these measures in your business.

Keeping radiation safety measures effective involves:

  • maintaining records to demonstrate that the hazard arrangements are being managed
  • appointing a Radiation Safety Officer for the radiation practice
  • periodic staff training on the Plan to ensure best work and radiation safety practices.

Appoint a Radiation Safety Officer to monitor radiation safety and compliance

At least one Radiation Safety Officer must be appointed for every radiation practice in your business.

The Radiation Safety Officer will monitor and inform you of the radiation safety status of your practice. Your Plan must detail the specific functions of the Radiation Safety Officer in your business.

Your Plan must require the Radiation Safety Officer to:

  • identify ways to minimise the radiation doses received by people
  • regularly review the plan to ensure it continues to be effective
  • monitor and report non-compliance with the plan and suggest ways to ensure compliance
  • monitor compliance with the Radiation Safety Act 1999, Plan and relevant radiation safety standard for the radiation source and premises
  • complete internal checks for compliance with the relevant radiation safety standard at a stated frequency.

Train staff on radiation hazard management and safe work practices

What staff training will the Radiation Safety Officer provide or organise?

Your Plan provides a guide for staff to effectively manage radiation hazards and implement safe work practices. It also describes their responsibilities under Radiation Safety Act 1999 to protect people and the environment from the harmful effects of the radiation used in your business.

All staff involved in any way with the radiation source will need to undertake training on their requirements and accountabilities as detailed in the Plan. This includes anyone working for you who may be exposed to radiation.

Training requirements

When detailing the training requirements, you should have a set of categories that staff will be allocated into depending on their role in the radiation practice and exposure to the radiation. Each category will require a different level of training to ensure radiation safety.

The training requirements will need to include the:

  • radiation hazards specific to your practice type
  • safe work practices
  • regulatory obligations of your staff
  • specific responsibilities for each staff radiation category you have identified
  • knowledge and skill required to deal with radiation hazards—based on the radiation category
  • steps to keep radiation doses received by any person as low as possible and below those listed in the Radiation Safety Regulation 2021
  • features of the radiation source and how you require it to be used.

Staff safety and radiation management knowledge and skills need to be maintained to ensure continued improvement in radiation safety in your business. This may be achieved by periodic training to refresh staff knowledge.

4. Incident response

What will you do if things go wrong?

Radiation incidents may occur as a result of a variety of events, including:

  • equipment error
  • deficient work practices
  • lack of safety equipment
  • equipment improperly used
  • a 'near miss' that could have resulted in an injury or exposure but did not
  • deficient administrative procedures or controls.

Your Plan should identify the radiation incidents that could happen in your radiation business and detail the processes and procedures you will have in place to minimise the potential hazard.

Your Plan needs to detail:

  • types of radiation incidents that could occur at your radiation practice
  • procedure to follow for each type of radiation incident that could occur
  • reporting requirements, including details of the written report given to the Possession Licensee, if an incident occurs.

The following must be immediately be reported to the department:

  • any incident occurring that has not been stated in your plan
  • if a radiation source is lost or stolen (or appears to have been)
  • radiation equipment malfunction that results in, or is expected to result in, unintended radiation emission.

Your Plan should require that copies of all incident reports be provided to the department.

Last updated: 21 November 2023