Radiation Management Plans are now mandatory in NSW
Kylie Robb, 1 September 2026.
Short answer: yes, your practice needs one. Since 1 September 2026, every NSW dental practice with an X-ray machine must have a completed Radiation Management Plan as a condition of its radiation management licence. The plan is one document setting out who is responsible, which machines are on the licence, who may use them, how patients and the team are protected, and what happens when something goes wrong. It is kept at the practice, read by the team, and produced when the EPA asks; it is never lodged.
What does a Radiation Management Plan cover?
One document setting out how the practice keeps X-rays safe and lawful: who is responsible, which machines are on the licence, who may use them and under what supervision, how patients and the team are protected, what training team members complete, and what happens when something goes wrong. It must be available to everyone who works with or around the machines.
What changed in 2025?
NSW rewrote its radiation rules in 2025. Since 1 December 2025, dentists and properly qualified dental assistants no longer need personal radiation licences for ordinary dental X-rays. The obligations moved to the practice: a management licence listing every machine, a current testing certificate for each one, verified qualifications for everyone who takes X-rays, a Quality Assurance Program, and, since 1 September 2026, the Radiation Management Plan that ties it together.
Do I have to use the EPA template?
No. The Regulation requires a plan that is prepared or adopted, implemented, available to everyone who works with or around the machines, and consistent with the ARPANSA codes. It does not prescribe a template or a set of headings.
The EPA publishes a template as a starting point. It sets out what the plan must cover and leaves the writing to the practice: the protection principles as they apply in your rooms, the justification and optimisation procedures, the quality assurance program, the training rules, the incident procedure. Around forty fields, close to half of them needing policy written rather than details entered.
The Radiation Compliance Kit (NSW) includes the Radiation Management Plan and Quality Assurance Program already written for a dental practice. The Kit is not a guide on how to write these documents yourself. The practice adds its details, makes three keep or delete choices, and the responsible person signs it off.
What do I need to do now?
If the plan is not yet done, the steps are the same as they were before the deadline. The difference is that the practice is already in breach, so the sooner it is finished the better.
- Find the radiation management licence and check every machine is listed. Confirm the renewal date; it renews every year.
- Find the NSW Certificate of Compliance for each machine and note the expiry dates. Machines are retested at least every five years.
- Confirm who takes X-rays. Registered practitioners are covered by Ahpra registration. Dental assistants need the Certificate IV in Dental Assisting (HLT45021) with the three radiography units from an EPA approved provider. CBCT operators need a personal user licence with condition IA24.
- Complete the Radiation Management Plan and Quality Assurance Program with the practice’s details.
- Have the responsible person, usually the owner or a director, sign the plan off, and tell the team where it is kept.
- Induct everyone who works in or around the clinical area on the finished plan, and keep a record of who has completed it.
Practices that already have a plan should check that it includes every machine on the licence and that everyone working around the machines has read your new Radiation Management Plan. A plan nobody knows about does not meet the requirement.
Step 6 is the one most practices still have ahead of them. The kit and the team training that goes with it are together on the dental radiation safety training (NSW) page.
Your Radiation documents are ready for you
Yes, the Radiation Compliance Kit (NSW) contains a fill-in Radiation Management Plan and Quality Assurance Program already written for a dental practice against the Protection from Harmful Radiation Regulation 2025, the Code for Radiation Protection in Dental Exposure (2025) and the EPA’s radiation standards. Every field needing the practice’s details is marked in yellow. Completing it is an afternoon’s work.
The Kit comes with clear leadership on where to start, what to do and where to find what you need. No dental or legal background is needed.
The kit includes:
- Radiation Management Plan template
- Quality Assurance Program template
- One page Radiation Compliance Register, the practice’s tracking file
- Final checklist: every box ticked, the practice is compliant
Hand the Kit to your practice manager or clinical coordinator and let them get on with it.
Who needs trained on the Radiation Management Plan?
The new Radiation Management Plan requires everyone who works in or around the clinical area to be inducted on it, not only the people who press the button. Dental Radiation Safety Training (NSW) is that induction. Each team member completes it under their own login and earns their own certificate for the radiation folder. The practice keeps one link for its induction checklist, so new starters complete the training as they arrive.
Pricing
The Radiation Compliance Kit (NSW) is $199 including GST, a one-time purchase.
Dental Radiation Safety Training (NSW) is available as a Practice Licence at $99 per year. One link covers the whole team with no limit on numbers, and renewing each year keeps the link live for new starters.
Last updated 22 September 2026.