
In Great Britain, IR(ME)R 2017 requires a dental practice's employer to provide for clinical audit "as appropriate" and for appropriate action on its results, with no interval set. The Guidance Notes for Dental Practitioners (2020) recommend image-quality grading and reject analysis every six months, and a check of the whole quality assurance programme at least once every three years.
What does IR(ME)R require on clinical audit?
The Ionising Radiation (Medical Exposure) Regulations 2017, IR(ME)R, apply in England, Wales and Scotland. Regulation 7 says the employer's procedures must provide for clinical audit "as appropriate" [1]. Since 1 October 2024 it also requires provision for "the taking of any appropriate action in relation to the results of such audit" [1][7]. The same amendment added a line to Schedule 2: the employer needs a written procedure for carrying out clinical audit and for any appropriate action that follows [2].
The regulations define clinical audit as a systematic review of medical radiological procedures against agreed standards, with practice modified where the review shows it should be [3].
The law sets no interval. Regulation 7, the Department of Health and Social Care (DHSC) guidance to the regulations and the Guidance Notes all leave it at "as appropriate" [1][9][10].
The DHSC guidance was updated on 4 September 2024 and says it is not binding [9]. It says the practice's procedure should describe how clinical audit is done locally, that results should be shared with everyone relevant, and that a re-audit should confirm the corrective action worked [9]. It also says it does not apply to Northern Ireland [9].
Northern Ireland has its own regulations, IR(ME)R (Northern Ireland) 2018. Their regulation 7 requires provision for clinical audit "as appropriate" and carries no wording on acting on the results. legislation.gov.uk lists no amendments to them [8]. The Guidance Notes read their own references to IR(ME)R 2017 as covering the Northern Ireland regulations too [10].
How should image quality be graded, and against what targets?
The Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment come from Public Health England and the Faculty of General Dental Practice (UK). The College of General Dentistry now publishes them and offers the 2nd edition (2020) [10][11][12]. That edition predates the 2024 amendments to IR(ME)R. The Guidance Notes use "must" for a legal requirement and "should" for a recommendation [10]. Their grading scheme is a recommendation.
Each radiograph is rated on a two-point scale: diagnostically acceptable (A) or not acceptable (N). This replaced the three-point scale of the first edition [10]. An A radiograph has no errors or minimal errors in patient preparation, exposure, positioning, processing or reconstruction, and is of sufficient quality to answer the clinical question [10].
The recommended targets are at least 95% of radiographs rated A for digital imaging and at least 90% for film [10]. The Guidance Notes describe these as achievable in the majority of well-managed dental practices [10]. Where a practice cannot meet them because of the patients it serves, it should consult its medical physics expert (MPE), set its own targets and record the reasons in its employer's procedures [10].
The ratings should be analysed at least once every six months, on a sample of at least 100 radiographs unless the workload is too low for that [10]. The rating can be prospective, as each radiograph is viewed, or retrospective, on a representative sample drawn from the records at regular intervals [10]. The person rating should be trained and experienced in taking the type of radiograph being rated [10]. Where a practice uses more than one modality, such as intraoral and panoramic radiography, the results are reported separately for each [10].
If the targets are persistently missed, the Guidance Notes recommend annual equipment testing in place of the usual interval of up to three years, subject to the MPE's advice [10].
The criteria for each grade are in Table 5.2 of the Guidance Notes [10]. Reject analysis in dental radiography sets out the scheme in full.
Where does reject analysis fit?
Reject analysis sits inside the image-quality part of the quality assurance (QA) programme. Every radiograph rated N gets a record of four things: the date, the nature of the deficiency, its known or suspected cause, and the number of repeat radiographs taken, if any [10]. The Guidance Notes recommend analysing those records at the same time as the image-quality analysis, every six months [10].
Grading asks whether each radiograph is good enough to answer the clinical question. Reject analysis asks why the N-rated ones fell short.
Clinical evaluation is a third, separate process. The Guidance Notes say it includes the interpretation of the image and the documentation of the findings, and keep it apart from image quality rating [10]. In Great Britain it is a legal duty: regulation 12(9) requires the employer to take steps to ensure a clinical evaluation of each exposure is recorded [5].
Which other radiography audits do the dental Guidance Notes recommend, and how often?
The Guidance Notes say clinical audits and/or peer reviews of radiography must be provided for, as appropriate. That "must" restates the legal duty. What they add is a recommended list of subjects [10]:
- the QA programme and its records
- the justification and authorisation of radiographs
- the clinical evaluation of radiographs
They set no interval for the audit of justification and authorisation or of clinical evaluation, and the law sets none for clinical audit [1][10]. Each should run under the appropriate national arrangements [10].
Two records make these audits possible. The authorisation process should let an audit identify who examined the patient and who authorised the exposure [10]. A clinical evaluation record should hold enough to be audited later, and the Guidance Notes say it does not need to be a full radiology report [10].
The person with overall responsibility for the QA programme should check the whole programme at intervals of no more than three years, and record the corrective action taken [10]. The employer's procedures should be reviewed whenever circumstances at the practice change, or otherwise at intervals of no more than three years [10].
The template procedure in Appendix D assigns an "annual audit of the records kept in support of the QA programmes" [10].
The Guidance Notes do not use the term "dose audit". Representative patient doses are measured at the acceptance test and at each routine equipment test, and reviewed against local diagnostic reference levels (DRLs) with the MPE's help [10]. Routine equipment tests are recommended at intervals of no more than three years [10].
In Great Britain, the employer's procedures must provide for the assessment of patient dose [2]. The equipment QA programme must permit dose assessment [6]. Since 1 October 2024 the employer must conduct local dose surveys where practicable, which the DHSC guidance says support local dose optimisation [4][9]. Where DRLs are consistently exceeded, the employer must ensure a review and corrective action where appropriate [4]. None of these carries an interval.
Records of QA checks and audits, and the employer's procedures, should be kept for at least five years [10].
| Audit or check | Law or recommendation | Where it is set | How often |
|---|---|---|---|
| Clinical audit, and action on its results | Law | IR(ME)R 2017 reg 7 and Sch 2 para 1(o), Great Britain [1][2]; IR(ME)R (NI) 2018 reg 7, Northern Ireland, without the action wording [8] | None set: "as appropriate" |
| Audit or peer review of the QA programme, justification and authorisation, and clinical evaluation | Recommendation | Guidance Notes 5.5 [10] | None set |
| Image-quality grading, A or N | Recommendation | Guidance Notes 5.4.1 and 5.4.2 [10] | At least every six months, on 100 or more radiographs |
| Reject analysis | Recommendation | Guidance Notes 5.4.3 [10] | Every six months, with the grading |
| Check of the whole QA programme | Recommendation | Guidance Notes 5.5 [10] | No more than three years in the body text |
| Review of the employer's procedures | Recommendation | Guidance Notes 5.1.1 [10] | When circumstances change, or no more than three years |
| Patient dose review against local DRLs | Recommendation | Guidance Notes 3.5.8 [10] | Regularly, including the doses measured at the acceptance test and each routine test |
| Routine equipment testing | Law in Great Britain, "at regular intervals"; interval recommended | IR(ME)R 2017 reg 15(3) [6]; Guidance Notes 5.2.3 [10] | No more than three years; annual, on MPE advice, if image-quality targets are persistently missed |
| Local dose surveys | Law in Great Britain | IR(ME)R 2017 reg 6(5)(e) [4] | None set: "where practicable" |
| Record of in-house equipment checks | Recommendation | Guidance Notes 5.2.4 [10] | At least once every six months |
| Digital receptor checks | Recommendation | Guidance Notes Table 5.1 [10] | Every three months, or whenever damage is suspected |
| Light-box and viewing conditions | Recommendation | Guidance Notes 5.3.4.3 [10] | No more than six months |
The sources on this page were checked on 23 September 2026.
Image-quality grading judges the radiograph. The two-minute reading test turns to your reading of it: what you catch, what you miss, and what to work on first.
References
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 7, "Employer's duties: clinical audit". Latest available (revised) version, as amended by SI 2024/896 from 1 October 2024. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, Schedule 2, "Employer's Procedures". Latest available (revised) version, as amended by SI 2024/896 from 1 October 2024. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 2, "Interpretation". Latest available (revised) version. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 6, "Employer's duties: establishment of general procedures, protocols and quality assurance programmes". Latest available (revised) version, as amended by SI 2024/896 from 1 October 2024. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 12, "Optimisation". Latest available (revised) version. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 15, "Equipment: general duties of the employer". Latest available (revised) version. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- UK Parliament. The Ionising Radiation (Medical Exposure) (Amendment) Regulations 2024, SI 2024/896, regulation 1. As made; in force 1 October 2024. legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- Statutory Rules of Northern Ireland. The Ionising Radiation (Medical Exposure) Regulations (Northern Ireland) 2018, SR 2018/17, regulation 7, "Employer's duties: clinical audit". legislation.gov.uk (The National Archives). Source (accessed 23 September 2026).
- Department of Health and Social Care. Guidance to the Ionising Radiation (Medical Exposure) Regulations 2017. GOV.UK, updated 4 September 2024. Source (accessed 23 September 2026).
- Public Health England and Faculty of General Dental Practice (UK). Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment. 2nd edition. London: PHE and FGDP(UK); 2020. ISBN 978-1-8381964-0-0. Sections 1, 3.2.2.2, 3.5.6, 3.5.7, 3.5.8, 5.1.1, 5.2.3, 5.2.4, 5.3.4.3, 5.4.1 to 5.4.3, 5.5, 6.3 and Appendix D. Source (accessed 23 September 2026).
- College of General Dentistry. Safe use of x-ray equipment. No date shown. Source (accessed 23 September 2026).
- College of General Dentistry. The Dental Guidance Notes, 2nd edition: what you need to know. 17 June 2024, updated 7 October 2024. Source (accessed 23 September 2026).
Dr. Wael Mansour
Papilla helps dental students, dentists, and dental hygienists learn to read radiographs, one real case at a time, against outlines drawn by expert annotators.